- 10 - 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 aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008