Oliver E. Stubblefield - Page 17

                                   - NEXTRECORD  -                                    
               Petitioner contends that his sister and cousin had income              
          but bad credit, whereas he had minimal income but good credit.              
          Therefore, according to petitioner, he permitted his sister and             
          cousin to trade on his credit and reimburse him in cash for                 
          expenditures made on their behalf.                                          
               Petitioner failed to prove the premise of his contention by            
          introducing credit reports or other documentary evidence showing            
          that his sister and cousin had bad credit.  Petitioner likewise             
          failed to prove that his sister was employed or had income in               
          1991.  In any event, the record demonstrates that petitioner's              
          credit cards and charge accounts were used only infrequently in             
          1991 and then only to make relatively modest purchases, with one            
          exception.  Thus, petitioner rarely used his American Express               
          card, and he never had a monthly balance greater than $100.                 
          Moreover, petitioner made no charges to his Citibank MasterCard             
          account, and he made but a single purchase (in the amount of                
          $23.70) using his Discover card.  In addition, petitioner made no           
          charges to his account with Foley's, and he made only one charge            
          (in the amount of $261) to his account with Metropolitan.                   
               Regarding the latter purchase, a prospective customer with             
          poor credit, including a history of repossessions, could probably           
          have obtained credit from Metropolitan with a $130 downpayment.             
          Thus, even if petitioner's sister or cousin had a bad credit                
          history, there was no showing that she could not have handled the           






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