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note; there is no stated interest; there is no fixed maturity
date; there is no payment schedule; there is no collateral; and
there is no evidence that such loans were repaid. While
petitioner testified that these withdrawals were part of the
claim of right later asserted by him and which he included in
income, petitioner has not provided any documentary evidence to
support his self-serving testimony. Some sort of objective
factors demonstrating economic reality are required. See Wilkof
v. Commissioner, 636 F.2d 1139 (6th Cir. 1981), affg. T.C. Memo.
1978-496. There are no such factors present here. Accordingly,
we hold that, to the extent that commissions received from
Lockheed, Goodyear, Clark, Galion, Morgan, or Ingersoll-Rand did
not constitute income to petitioner in the years they were paid,
the withdrawals from the Diesel Power Bank of America account
which were converted to petitioner's personal use constituted
either constructive dividends or converted funds. In either
case, those withdrawals constituted income to petitioner in the
years of withdrawal.
III. Issues 4 and 5--Interest Income on Foreign Bank Accounts
In the years 1974 and 1975 petitioner had a bank account
with First National City Bank in London (FNCB), account number
1612131. The account earned interest for those years in the
amounts of $38,055.71 and $43,641,69, respectively. Petitioner
owned the account; he was the sole signatory to the account; he
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