Faith J. Larsen - Page 10




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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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