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specifically indicated that the disbursements were loans from
petitioner’s respective annuity policies. Other than his bare
assertions that he did not take any loans against the policies,
petitioner presented no documentary evidence to demonstrate that
the 1999 disbursements were anything other than loans against the
policies. Moreover, petitioner presented no evidence, aside from
his self-serving statements, that he did not receive the
distributions as reported in the Forms 1099-R for 2001. See
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986) (“we are not
required to accept the self-serving testimony of petitioner * * *
as gospel”). Indeed, petitioner submitted signed Surrender
Request forms for each policy in or about May and June 2001, the
year in which he received the distributions at issue. Pursuant
to petitioner’s Surrender Request forms, Americo distributed to
petitioner the full cash surrender value of each annuity policy
in June 2001. Thereafter, Americo issued Forms 1099-R indicating
such distributions. Accordingly, we conclude that petitioner
received a total distribution of $24,146 from Americo in 2001.
2. Are the distributions at issue includable in
petitioner’s gross income?
As relevant to the instant case, annuities purchased by a
tax-exempt educational organization for the benefit of its
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