- 16 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16
Last modified: May 25, 2011