Ernesto H. Monroy - Page 17

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          corporation, Grupo Empresarial Monyurri (Grupo), and gave                   
          petitioner's wife and children the stock of Grupo.  He testified            
          that he is not good with numbers but, when he had an idea for a             
          business, he would pitch it to his family and they would give him           
          the money in the form of a loan.  Petitioner previously asserted            
          that the loans were from a Mexican company, although he did not             
          provide an explanation as to why a Mexican company would loan               
          money to petitioner or to Interservice.                                     
               Petitioner asserts that it is "totally believable and                  
          consistent that petitioner was able to borrow $1,115,967 from his           
          family and his family's corporation", because banks were willing            
          to lend money to petitioner.  Petitioner cites various loans,               
          including the loans on the house and lots in the Dominion, to               
          corroborate this assertion.                                                 
               The bank loans that petitioner received were based on                  
          information provided on loan applications.  Petitioner stated on            
          the loan application for the house in the Dominion that his gross           
          monthly income was $30,000.  According to petitioner's testimony,           
          however, his family was aware that he did not have income.  It is           
          not credible that loans in the amounts claimed would be made to             
          someone with no income from which to repay the loans.                       
               Petitioner also argues that two sets of documents                      
          substantiate his claim of loans in 1990, the UCC financing                  
          statement and the ledger sheet, with promissory notes in Spanish,           
          given to respondent in 1994 during the audit.  G. Rodriguez                 




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