Ronald L. DeVault - Page 11

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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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