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The offers that preceded the $160,000 payment related to
petitioner’s role as an employee. Those offers were either to
reward petitioner’s performance or to induce her to remain in the
Seattle area.
Although petitioner and Mr. Hoiland worked together and were
close acquaintances, there was no romantic relationship between
them. Petitioner did not travel with Mr. Hoiland, and their
social relationship did not transcend their work relationship.
Although Mr. Hoiland made one sexual advance, petitioner flatly
rejected it. These facts suggest that the $160,000 payment was
motivated by business exigencies and not by detached or
disinterested generosity. See Duberstein v. Commissioner, supra
at 285.
Considering the record as a whole, we find that petitioner’s
uncorroborated testimony that Mr. Hoiland had an unrequited
romantic interest in her or that she was the only employee to
receive a substantial payment at the end of the year is
insufficient to support her contention that the payment was a
gift. We are not required to accept the self-serving testimony
of interested parties without persuasive evidence or
corroboration. See Tokarski v. Commissioner, 87 T.C. 74, 77
(1986); Yang v. Commissioner, T.C. Memo. 2000-263.
PCI’s issuance of a Form 1099-MISC reporting the $160,000
payment indicates that PCI did not intend this payment to be a
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