- 35 -
Q And the advice of your CPA was you did not
have to pay tax?
A No.
Q No, it was or --
A I didn't get any advice in regard to tax,
paying any tax.
Q Your accountant told you, You do not have
to pay tax on any of these loans that you
received?
A No. He did not say that. The only thing
that he said was that we need to devise a plan to
pay off these loans.
Q Did he advise you that you didn't have to
pay off those loans?
A No.
Thus, while the record contains petitioner's self-
serving testimony that he and Mrs. Garcia relied upon the
advice of Mr. Glen, we find petitioner's testimony to be
vague, conclusory, and contradictory. Indeed, petitioner's
testimony on cross-examination is that he "did not get any
advice [from his accountant] in regard to tax, paying any
tax." Accordingly, this is not a case in which we are
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