- 24 -
mentioning that there were tax benefits of making such an
investment. Petitioner testified that she inquired into the
legality of these tax benefits.
We do not accept petitioner’s testimony as reliable evidence
concerning the meeting with Mr. Hoyt, a meeting that occurred
approximately 22 years prior to trial. The testimony is self-
serving and uncorroborated, and we therefore are not required to
accept it as credible evidence. See Niedringhaus v.
Commissioner, 99 T.C. 202, 212, 219-220 (1992); Tokarski v.
Commissioner, 87 T.C. 74, 77 (1986). Furthermore, we find
certain details provided by petitioner to be contradictory. For
example, while petitioner testified that she did not want to be
at the meeting and that she was completely uninterested in the
subject matter being discussed, she testified that she recalls
that she asked specific questions concerning Mr. Hoyt’s
credentials and the legality of the investment. We also do not
accept that petitioner, with her level of education and
background, would have been present at the sales meeting without
realizing it was in fact an attempt to sell petitioner and Mr.
Barnes an investment.
Petitioner further testified that she was unaware that Mr.
Barnes signed any investment papers prior to the time they filed
their 1981 joint return: It was only when she signed the return
that she learned Mr. Barnes had decided to invest in the
Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: May 25, 2011