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credit card liabilities. However, the total reflected on
petitioners' 1990 schedule should be reduced by the balance of a
corporate credit card and by a balance for which there is no
supporting monthly statement. The total reflected on
petitioners' 1991 schedule should be reduced by the balances of
two corporate credit cards and increased by $100 to correct an
apparent mathematical error. Because, during 1989, petitioners
operated L.A. Trading as a sole proprietorship, we need not
reduce the total reflected on petitioners' 1989 schedule by the
business (corporate) credit card. We have determined from the
evidence that petitioners had the personal credit card balances
set forth in our Findings of Fact. Respondent's calculations of
petitioners' net worth for 1990 and 1991 must be adjusted to
reflect the credit card balances as liabilities.
b. Debts to friends and relatives. Petitioners contend
that respondent failed to take into account several liabilities
that petitioners incurred to various friends and relatives.
Yoon testified at trial that he borrowed $30,000 in 1990 and
$3,000 in 1991 from Doo Sung. Doo Sung also testified to the
existence of these loans. Their testimony regarding the $30,000
loan in 1990 was corroborated by a copy of Doo Sung's checking
account statement for a period ended October 25, 1990, that
showed that a check in the amount of $30,000 had cleared the bank
on October 22, 1990. Yoon's and Doo Sung's testimony regarding
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