Diep N. Hoang - Page 8

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          deposit”).  Petitioner also testified that the Strong account he            
          opened was not an IRA account even though he stipulated to the              
          contrary, the documentary evidence is to the contrary, and he               
          testified that he sent the money from Mellon Bank to Strong as an           
          IRA direct transfer.                                                        
               Under the circumstances, 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.  See           
          Lerch v. Commissioner, supra; Geiger v. Commissioner, supra;                
          Tokarski v. Commissioner, supra.  The Court is not required to              
          accept petitioner’s unsubstantiated testimony.  See Wood v.                 
          Commissioner, 338 F.2d 602, 605 (9th Cir. 1964), affg. 41 T.C.              
          593 (1964).  The Court need not accept at face value a witness’s            
          testimony that is self-interested or otherwise questionable.  See           
          Archer v. Commissioner, 227 F.2d 270, 273 (5th Cir. 1955), affg.            
          a Memorandum Opinion of this Court; Weiss v. Commissioner, 221              
          F.2d 152, 156 (8th Cir. 1955), affg. T.C. Memo. 1954-51;                    
          Schroeder v. Commissioner, T.C. Memo. 1986-467.                             
               There is no evidence that petitioner filed Forms 8606.  The            
          evidence does not establish the initial source of the funds in              
          the Janus IRA or that petitioner has any basis (“investment in              
          the contract”) in the Janus IRA.  Accordingly, we sustain                   
          respondent’s determination regarding petitioner’s IRA                       
          distributions for 2001.                                                     

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