Fernando and Maria Leonzo - Page 5

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          $13,342 reported income from L&L and the $20,896 in L&L checks              
          that petitioners deposited were loans.                                      
               Petitioners have scant evidence to support their                       
          contentions.  With respect to the $60,000 from LIC, petitioners             
          offered incomplete loan documents, including a copy of a check              
          from LIC payable to LCC and a promissory note in which payment              
          terms were left blank.  Petitioners' documents are insufficient             
          to establish a bona fide loan.  Petitioner testified that he did            
          not make any payments to LIC and that he did not provide any                
          security or collateral for the alleged loan.  Petitioner, as an             
          owner and officer of the company, had control in the decision of            
          whether or not to enforce the alleged debt.  He has failed to               
          prove that the distribution of $60,000 to him was not his share             
          of profits from LIC or compensation to him for services to LIC.             
               Petitioners offered only uncorroborated testimony with                 
          respect to the L&L loans.  Petitioner testified that the                    
          president of L&L often asked petitioner for a "personal loan of             
          two, three hundred, four hundred dollars, and then I gave the               
          money to him, and when he paid me back, he made a check of L&L              
          Construction also on my name."                                              
               Petitioner's explanation for the amounts received from L&L             
          is not credible.  The L&L checks that petitioner received were              
          dated at regular intervals throughout 1988.  Some were clearly              
          payroll checks.  Others, in the amounts of $500 or $1,000, were             
          marked "Professional services."   Petitioner testified that he              




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