Lawrence Robert Clifton-Bligh - Page 5

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          incurred or sustained losses regarding Lloyd’s during the years             
          in issue.                                                                   
               Mr. Swain’s testimony does not support petitioner’s                    
          assertion that he invested money in, or suffered a loss related             
          to, SJC.  Mr. Swain had no personal knowledge regarding whether             
          (1) the money he received from Mr. Conway originally came from              
          petitioner, (2) the money was given to Mr. Conway or SJC, or (3)            
          the money was an investment or a loan.  Mr. Swain did not see any           
          documentation regarding where the money Mr. Conway paid him came            
          from.  Furthermore, Mr. Swain did not testify regarding whether             
          SJC went bankrupt.                                                          
               Additionally, we note that Mr. Conway and Mr. Marisco were             
          not called as witnesses.  We infer that their testimony would not           
          have been favorable to petitioner.  Wichita Terminal Elevator Co.           
          v. Commissioner, 6 T.C. 1158, 1165 (1946), affd. 162 F.2d 513               
          (10th Cir. 1947).                                                           
               We found petitioner’s testimony to be general, vague,                  
          conclusory, and/or questionable in certain material respects.               
          Under the circumstances presented here, we are not required to,             
          and generally do not, rely on petitioner’s testimony to sustain             
          his burden of establishing error in respondent’s determinations.            
          Lerch v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989),               
          affg. T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688,            

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