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demeanor at trial, we do not consider petitioner's testimony to
be credible. Moreover, the records relied on by petitioner are
inconclusive and do not establish that the amounts charged and
paid by Pieces of Eight were expenditures of a business, rather
than of a personal, nature. Indeed, based on the information in
the charge account statements, many of the charges listed appear
indistinguishable from personal expenses. Petitioner’s claim
that other expenditures were loans that were subsequently repaid,
even if we were to accept it, does not call into question
respondent’s determination. In essence, respondent determined,
on the basis of the expenditures by Pieces of Eight, that Pieces
of Eight received taxable income that enabled it to make those
expenditures. Petitioner did attempt to show a nontaxable source
for the expenditures, claiming money obtained from refinancing a
mortgage on his home provided funds that were advanced to Pieces
of Eight in 1987, and that additional funds were advanced through
the end of 1990. Petitioner’s testimony on the matter, however,
was vague, confusing, and contradictory, and we do not accept it.
Moreover, petitioner did not have a large amount of assets after
the bankruptcy of Cape Town, which concluded in 1988. We also
conclude that petitioner was an owner of Pieces of Eight during
1988 and 1989. We accordingly hold that petitioner has failed to
carry his burden of demonstrating error in respondent’s
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