- 32 -- 32 -
We are unwilling to accept either petitioners' schedules of
expenses or Ms. Harp's testimony as reliable evidence to support
petitioners' contention. Petitioners' schedules of expenses,
like Ms. Harp's testimony about those schedules, are nothing more
than self-serving statements that the additional disbursements
from petitioners' accounts during the years at issue that are
reflected in those schedules were made to, or on behalf of, K & H
and Ms. Velilla. Neither petitioners' schedules of expenses nor
Ms. Harp's testimony, which we found to be general, vague,
conclusory, and at times internally inconsistent, persuade us
that those additional disbursements were, in fact, made to, or on
behalf of, K & H and Ms. Velilla, rather than in payment of
petitioners' expenses.20 In this connection, Ms. Harp testified
that petitioners' schedules of expenses were prepared in reliance
on copies that petitioners were able to obtain of certain
supplier bills and canceled checks, which, she claims, indicated
thereon the purposes for which certain disbursements from
20 We note that, with respect to $9,689.80 of the additional
disbursements that petitioners claim they made during 1990 to, or
on behalf of, K & H and Ms. Velilla, they also claim that they
paid that same amount during that same year to Mr. Kabeiseman in
partial repayment of the $29,000 in Kabeiseman loans that peti-
tioner received in 1989. The record establishes that the pay-
ments totaling $9,689.80 that petitioners made during 1990 were
made to Mr. Kabeiseman in partial repayment of the Kabeiseman
loans. Thus, not only are petitioners wrong in contending that
those payments were made to, or on behalf of, K & H and Ms.
Velilla, they are counting those payments twice, once in advanc-
ing their argument with respect to the Kabeiseman loans and once
in advancing their argument with respect to the deposits of K &
H's and Ms. Velilla's funds.
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