Judith A. Madden - Page 16

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         totaling $620,000, has a value between $850,000 and $950,000.                
         Petitioner also testified that she placed the New York property              
         on the market for $82,000 during the summer and fall of 2001, but            
         she did not receive any firm offers.  Petitioner claims that her             
         net worth is approximately $50,000.                                          
              Petitioner did not produce bank records, property tax                   
         assessments, real estate appraisals, the listing agreement for               
         the New York property, or any other evidence to support her                  
         testimony.  Neither Mr. Sturges nor any representative from Paine            
         Webber or Cisco testified at the trial.  The only record from                
         Paine Webber is a one-page statement for August 2001 that shows              
         petitioner and Mr. Sturges having an account with a value of                 
         $13,439.34.  Petitioner offered no evidence other than her own               
         testimony that (1) there is only $15,000 remaining in the                    
         charitable remainder trust, (2) monthly expenses exceed Mr.                  
         Sturges’s monthly income by $3,500, (3) petitioner and Mr.                   
         Sturges’s residence has a value of less than $950,000, (4) the               
         unencumbered New York house has a value of less than $82,000, and            
         (4) the land in Colorado has a value of $20,000.  In the absence             
         of corroborating evidence, we are not required to accept, and do             
         not accept, petitioner’s self-serving testimony.  See Tokarski v.            
         Commissioner, 87 T.C. 74, 77 (1986).                                         
              Consequently, we conclude that petitioner has failed to                 
         carry her burden of proving that requiring her to pay the                    

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