-33-
the court of appeals may well find clear error even in
a finding purportedly based on a credibility
determination. See, e.g., United States v. United
States Gypsum Co., supra, [333 U.S.] at 396. But when
a trial judge’s finding is based on his decision to
credit the testimony of one of two or more witnesses,
each of whom has told a coherent and facially plausible
story that is not contradicted by extrinsic evidence,
that finding, if not internally inconsistent, can
virtually never be clear error. Cf. United States v.
Aluminum Co. of America, 148 F.2d 416, 433 (CA2 1945);
Orvis v. Higgins, supra, at 539-540. [Id. at 575-576;
emphasis added.]
Consistent with the foregoing, and in the light of the
Courts of Appeals’ directions to this Court on remand, we are
obliged to review the recommended findings of fact and
credibility determinations set forth in the STJ report under a
“manifestly unreasonable” standard of review, and we may reject
such findings of fact and credibility determinations only if,
after reviewing the record in its entirety, we conclude that the
recommended finding of fact or testimony (1) is internally
inconsistent or so implausible that a reasonable fact finder
would not believe it, or (2) is not credible because it is
directly contradicted by documentary or objective evidence. Id.
at 574-575; see Boyett v. Commissioner, 204 F.2d 205, 208 (5th
Cir. 1953) (a court may reject positive and uncontradicted
testimony as to a particular fact if the testimony “is inherently
improbable or manifestly unreasonable, even though no
contradictory testimony is offered” (emphasis added)), affg. a
Memorandum Opinion of this Court; Stone v. Commissioner, 865 F.2d
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