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testified that petitioner obtained the UCC financing statement to
protect his personal items from levy for unpaid taxes. Her
testimony is consistent with the sequence of events established
by the evidence.
The ledger sheet and promissory notes that were given to
respondent in 1994 are unreliable. G. Rodriguez and the revenue
agent both testified that they had been informed that there were
no loans from petitioner's family. The documents were not
provided to the IRS until 1994, 2 years after the agent requested
the information. Additionally, the address on the December 1990
invoice was listed as Ave. Hidalgo, #407 in Toluca, Mexico.
Petitioner was residing in San Antonio at the Dominion in 1990.
The address on the invoice was the address that petitioner used
after returning to Mexico in 1991.
Petitioner also argues that the 200,000,000 pesos deposited
in his account at Banca Cremi was a loan and that petitioner
planned to use the proceeds of that loan to pay back the family
loans. The only document in evidence on this point is a deposit
slip in Spanish for 200,000,000 pesos deposited into a bank
account. There are no loan documents or any indication that the
deposit was a loan or that the proceeds were going to be used in
any particular manner. Further, using petitioner's exchange rate
of 2,889 pesos per dollar, the 200,000,000 pesos would convert to
approximately $69,228, an amount insignificant in comparison to
the total amount that petitioner claims to owe his family.
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