-19-
this wire transfer does not support petitioner's testimony
because the transfer was sent to Saleh, not to petitioner.
Accordingly, without evidence corroborating petitioner's claim
that Saleh transferred the funds he received to petitioner, the
copy of this wire transfer does not show that petitioner received
any funds from his family.
Petitioner also introduced his check register into evidence
to corroborate his claim that he made many loans to friends.
Petitioner's reliance on his check register settles on a single
entry that verifies he issued a check on December 8, 1991, for
$1,000 to "Guss". This single entry is woefully inadequate to
perform the task petitioner would assign it. The entry does not
indicate the purpose of the amount paid, the intent of the
parties, or any of the other indicia necessary to substantiate
the existence of a loan.18 We find this entry in petitioner's
check register does not provide documentary evidence to establish
the existence of the claimed loans.
Petitioner's claim that he paid the bills of others by check
and received cash reimbursements which he deposited suffers from
18 Factors which have been considered by courts as relevant in
deciding whether a bona fide loan exists include among others:
(1) The existence or nonexistence of a debt instrument; (2)
provisions for security, interest payments, and a fixed repayment
date; (3) whether or not repayments of the loan were made; (4)
the taxpayer's ability to repay the loan; (5) the borrower's
receipt of compensation; and (6) the testimony of the taxpayer.
Frierdich v. Commissioner, T.C. Memo. 1989-393, affd. 925 F.2d
180 (7th Cir. 1991).
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