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not remember whether that deposit was a partial repayment of the
$14,000 that he testified that he lent to Libutti or a redeposit
of a previous withdrawal. With respect to the deposit of $1,700
to the North Fork account on March 24, 1987, petitioner testified
that he had no specific recollection of that deposit, although it
could be another partial repayment from Libutti. With respect to
the deposit of $1,004 to the North Fork account on March 17,
1987, petitioner testified that he had no recollection as to its
nature. By his testimony, petitioner did not convince us that
the 1987 North Fork deposits were either loan repayments or
redeposits.
Petitioner has not directed us to any testimony (or other
evidence) with respect to the source of the deposit of $7,000 to
the Astoria account on September 11, 1987, or the payment of
$4,000 to North Fork on June 26, 1987. Petitioner has failed to
convince us that either item is either a loan repayment or a
redeposit of a previously withdrawn sum.
Petitioner has convinced us, however, that the deposit of
$1,000 to the Astoria account on December 28, 1987, is the
redeposit of $1,000 withdrawn from the North Fork account, and we
so find.
With respect to (1) all of the 1987 deposits to the North
Fork account, (2) the September 11, 1987, deposit to the Astoria
account, and (3) the June 26, 1987, payment to North Fork,
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