Joseph C. Minneman - Page 14

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         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                

               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                   
                    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,                

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