William L. Richter - Page 16

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          return claims that HEH had distributable net income and actually            
          made income distributions of $316,526, the return was not                   
          prepared until after petitioner filed his petition in this case             
          and is simply not probative or trustworthy.  HEH’s amended return           
          was signed by Mr. Sparkman less than 1 month prior to trial and             
          is not corroborated by any credible evidence.  In the absence of            
          corroborating evidence, we are not required to accept the self-             
          serving testimony of petitioner or other interested witnesses.              
          Bose Corp. v. Consumers Union of U.S., Inc., 466 U.S. 485, 512              
          (1984); Day v. Commissioner, 975 F.2d 534, 538 (8th Cir. 1992),             
          affg. in part, revg. in part on another ground and remanding T.C.           
          Memo. 1991-140; Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).            
               Because we are not convinced on this record that any part of           
          HEH’s income was allocable to petitioner or that HEH allocated a            
          portion of its investment in qualifying energy property to                  
          petitioner for 1995, we hold that petitioner is not entitled to             
          the $513 energy credit claimed on his 1995 return.                          
               We have carefully considered all remaining arguments made by           
          petitioner for contrary holdings and, to the extent not                     
          discussed, find them to be irrelevant or without merit.                     
               To reflect the foregoing,                                              

                                                  Decision will be entered            
                                             for respondent.                          

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