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offered no explanation as to how he would realize a greater
return by holding the money in cash in his home. Since
petitioner's rationale for the loan defies common sense and we
find petitioner's testimony uncorroborated by the evidence,
petitioner has not met his burden of proof, and he must include
the $50,000 in his 1986 income.
Third, petitioner asserts that deposits totaling $2,800,
$4,900,2 and $8,400 for 1985, 1986, and 1987, respectively,
constituted nontaxable distributions from Diamond Shamrock, and
that a deposit of $5,022 in 1987 constituted a nontaxable
distribution from Union Exploration. Petitioner attempted to
prove this assertion based on security account statements
indicating distributions from Diamond Shamrock and Union
Exploration. These statements, however, merely indicate that
petitioner received distributions, not that he cashed the
distribution checks and then deposited the cash into his ACB
account. Petitioner did not have deposits in his ACB account
which corresponded to amounts of the distributions; rather,
petitioner would have us aggregate various deposits in the
amounts of the distributions. Also, when his attorney asked him
if the dividends from the Diamond Shamrock and Union Exploration
investments were deposited into his ACB account, petitioner
testified that he "would assume" they all went in. Since
2 The parties stipulated that the amount of the Diamond
Shamrock distributions at issue for 1986 was only $4,900.
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