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failure to offer corroborative testimony that they held funds as
nominees is a significant factor in determining that they failed
to carry their burden of proof). We conclude that USB account
0894 was Walter's account, maintained in the name of
Reprographics.
Walter testified that Reprographics conducted no business in
the United States except that it purchased certain second
mortgages. Checks written on USB account 0894 from November 1985
through December 1987 are in evidence. Some of those checks
clearly fail to relate to the purchase of second mortgages. For
example, USB account 0894 check numbers 6902 and 6907, in the
amounts of $1,200 and $2,000, respectively, were issued in
December 1985, and drawn to "Northwest Dance Center". On brief,
with no citation to the record, petitioners explain those checks
as loans, apparently unsecured, "to help a struggling arts
group". USB account 0894 check number 6979, in the amount of
$1,500, was issued in October 1986, and drawn to "Walter J. Van
Eck". On brief, petitioners claim, with the citation of nothing
other than the letters "ln" on the check, that such check
represented a loan to Walter (subsequently repaid). As to
numerous checks that, on brief, petitioners concede were mortgage
payments on properties owned by them, petitioners argue that such
checks were payments on the "Universal Finance second mortgage"
that Reprographics "was purchasing on contract (see the
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