Haralampos Katerelos and Irene Katerelos - Page 54

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            purposes.  Thus, according to that insurance form, Mr. Katerelos                              
            was not using the Lincoln for business purposes, and his testi-                               
            mony is inconsistent with that form.                                                          
                  With respect to the summary of the automobile expenses at                               
            issue that Mr. Katerelos reconstructed, we did not find that                                  
            self-serving and uncorroborated reconstruction to be credible.                                
            In addition to our having found that Mr. Katerelos' testimony is                              
            generally not credible, we question how he could have remembered                              
            enough specific facts to prepare that summary when he testified                               
            on various occasions that he did not remember specific facts when                             
            questioned by counsel for respondent.41  We also question the                                 
            validity of the summary of automobile expenses that Mr. Katerelos                             
            prepared, since he claimed therein that (1) he traveled five                                  
            times a week to a branch of his bank that was 10 miles away from                              
            NDV when another branch was located approximately .7 miles from                               
            NDV and (2) he continued to visit a Price Club once a week that                               
            was 10 miles from NDV even after a new Price Club opened in 1988                              
            that was only .2 miles from NDV and to which he wrote all of the                              
            checks that he wrote to Price Club subsequent to its opening.                                 
                  Based on our review of the entire record before us, we find                             
            that petitioners failed to prove that they are entitled to                                    

            41  For example, when asked whether construction on the swimming                              
            pool that petitioners had installed was started in May 1989, Mr.                              
            Katerelos responded, "I don't remember dates."  Similarly, when                               
            asked whether he installed a $3,500 barbeque and patio, he                                    
            responded, "I don't recall amounts."                                                          




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