- 13 -
1970-335; MacGuire v. Commissioner, 450 F.2d 1239, 1244 (5th Cir.
1971) (same), affg. T.C. Memo. 1970-89; Niedringhaus v.
Commissioner, 99 T.C. 202, 212 (1992) (“The Court is not required
to accept petitioner’s self-serving testimony.”); Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986) (“we are not required to
accept the self-serving testimony of petitioner * * * as
gospel”). Thus, by way of example, we regard as a flight of
fancy petitioner’s assertion that his personal notes and books
from law school, which he attended from 1967 to 1970, together
with some plaques and trophies “and things like that” from his
days as a member of a local school board in the mid-1960s, had an
adjusted basis of $7,150 and a fair market value of $6,200 in
1989.5
5 The following colloquy between the Court and petitioner
is particularly revealing:
THE COURT: So a law student going to law school,
let’s say, in 1989 or 1990 –- do you think they would
be willing to pay $5,000 for these 20-year-old books in
lieu of buying current books at the law school?
PETITIONER: Well, now, I don’t want to be
facetious, Your Honor. I do know –-
THE COURT: You’re having trouble keeping a
straight face, so I think you’ve kind of given us an
answer.
PETITIONER: No, I’m not laughing about that. I
was thinking of something that occurred when I was
going to law school. It was when we freshmen came in,
there was always a sophomore or senior who was always
willing to sell us a book that we –- wasn’t being used,
(continued...)
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011