- 54 -
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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