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a shareholder of his or her shares by redeeming a shareholder’s
shares subject to certain limitations, Wash. Rev. Code Ann. sec.
23B.06.400(1), (4)(b)(i) (West 2001), or by seeking judicial
dissolution of the corporation, Wash. Rev. Code Ann. sec.
23B.14.300 (West 2001).
Petitioner contends that he was not a shareholder of Union
Machine in 2000 because he forfeited his ownership interest in
Union Machine in September 1999. In support of his contention,
petitioner relies on his declaration stating that he forfeited to
Mr. Turner his 49-percent share in Union Machine in September
1999. However, the May 14, 2003, declaration signed by
petitioner after the filing of the petition, which declaration
Mr. Turner refused to sign, is nothing more than a self-serving
statement. We are not compelled to accept petitioner’s
unsubstantiated, conclusory, and self-serving statement without
additional evidence. See Johnson v. Commissioner, T.C. Memo.
1999-127, affd. 246 F.3d 674 (9th Cir. 2000).
In addition, the evidence in the record contradicts
petitioner’s declaration. Petitioner testified at trial that he
actually left Union Machine in 1998, but that he wrote down
September 1999 only because he was instructed by an IRS agent
during an audit to list a date for the time period at issue.
Therefore, we do not regard petitioner’s declaration to be
determinative that petitioner was not a shareholder in 2000.
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