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1993 U.S. Dollars Korean Won Equivalent
Bok Rye Kim $440,324 1350 million
Sung Bae Kim 246,354 200 million
Ki Soon Yun 70,000
Young Ae Hong 187,676 150 million
_________
Total: 944,354
1994 U.S. Dollars Korean Won Equivalent
Bok Rye Kim $491,672 400 million
Sul Ja Kim 100,000
Mr. Moon 20,000
Il Sup Cha 184,377 150 million
_________
Total: 796,049
1Petitioners claim that several of the loans were paid in
Korean currency and later converted to U.S. dollars before being
deposited into the TBJ account. In these instances, the U.S.
dollar amounts represent the agreed conversion value.
a. Nontestifying Lenders
Of these seven individuals, only Bok Rye Kim testified at
trial. Petitioners did not explain the absence of the other six,
all of whom were relatives of petitioners.4 We cannot assume
that the testimony of absent witnesses would have been favorable
to petitioners. Indeed, we infer that it would have been
unfavorable. See McKay v. Commissioner, 886 F.2d 1237, 1238 (9th
Cir. 1989), affg. 89 T.C. 1063 (1987); Pollack v. Commissioner,
47 T.C. 92, 108 (1966), affd. 392 F.2d 409 (5th Cir. 1968);
Wichita Terminal Elevator Co. v. Commissioner, 6 T.C. 1158, 1165
(1946), affd. 162 F.2d 513 (10th Cir. 1947).
4At least two of these purported lenders, Ki Soon Yun and
Mr. Moon, resided in San Francisco.
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