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and $180,000 in 1990 or were so-called accommodation deposits2
from Sergio Antonucci (Mr. Antonucci) in the amounts of
$30,000 on January 5, 1989, $7,5003 on March 31, 1989, and $5,000
on May 15, 1989, through an account under the name of Morgan
Stern Group during 1989.
Mr. Zurn testified that he lent petitioner approximately
$700,000 over the years in question. With the exception of a
copy of an alleged journal pertaining to funds received from Mr.
Zurn to construct an apartment building, see discussion infra,
there are no documents showing transfers of funds between
petitioner and Mr. Zurn. During this time petitioner did perform
services for Mr. Zurn and/or Zurn-related activities.
With regard to the NOL carryovers, petitioner alleges that
he suffered an NOL in 1984 in the amount of $146,058, which,
together with a carryover from prior years in the amount of
$4,907, produced an NOL carryover in the amount of $150,965.
Petitioner introduced a copy of his 1984 return that was
allegedly filed and included, inter alia, a Schedule C reporting
2 As we understand it, Mr. Antonucci would allegedly send
money to petitioner's account, and then later petitioner would
pay the money to Mr. Antonucci or have it paid on the latter's
behalf.
3 The transcript refers to this amount as $75,000. The
exhibit to which the testimony related shows $7,500 to be the
actual amount.
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