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Petitioner argues that the deposits to Interservice in 1991
could not have come from him because the amounts were not
recorded as loans from shareholders on the books. On brief,
petitioner's position is that the amounts in issue are loans from
his wife. Petitioner supports this assertion by pointing to a
check from petitioner to his wife, which is purportedly a payment
on the loans owed to his wife.
Both G. Rodriguez and Esquivel testified that they traveled
to Mexico to meet with petitioner and his daughter. G. Rodriguez
testified that the reason for the meeting was to "create backup"
for the transfers of money to petitioner and Interservice so that
it appeared that the money was not income to petitioner.
Esquivel testified that the purpose of the trip was to compare
numbers. G. Rodriguez testified that, while she and Esquivel
were in Mexico, petitioner gave instructions to record the
amounts as transfers from a "Mexican Company". Approximately
2 months after the trip to Mexico, Esquivel sent to Bradley a
letter listing the deposits to Interservice from Mexico.
Esquivel did not indicate in the letter to Bradley that the
deposits were loans. On an Interservice ledger sheet, the
amounts were listed as payable to a "Mexican Company" and
Gabriela Monroy. One of the deposits was listed as from Cable
Leon.
The evidence supports respondent's assertion that the
deposits to Interservice were not loans but income to petitioner
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