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F.2d 928, 931 (7th Cir. 1960) (legal relationship between closely
held corporation and its shareholders as to payments to the
latter “must be established by a consideration of all relevant
factors indicating the true intent of the parties.”), affg. T.C.
Memo. 1959-225; Kaplan v. Commissioner, 43 T.C. 580, 595 (1965).
We note at the outset that petitioner was not a credible
witness. We found his testimony implausible and unconvincing.
It was at times vague, evasive, self-serving, and contradictory.
He had selective recall relating to the 1987 and 1988
transactions and the assets in issue in the instant case. We are
not required to accept self-serving testimony, particularly where
it is implausible and there is no persuasive corroborating
evidence. E.g., Frierdich v. Commissioner, 925 F.2d 180, 185
(7th Cir. 1991) (“The statements of an interested party as to his
own intentions are not necessarily conclusive, even when they are
uncontradicted.”), affg. T.C. Memo. 1989-103 as amended by T.C.
Memo. 1989-393; Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th
Cir. 1989), affg. T.C. Memo. 1987-295; Tokarski v. Commissioner,
87 T.C. 74, 77 (1986). Additionally, a taxpayer’s testimony as
to intent is not determinative, particularly where it is
contradicted by the objective evidence. Busch v. Commissioner,
supra at 948; Glimco v. Commissioner, 397 F.2d 537, 540-541 (7th
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