- 101 -
With respect to the checks totaling the $27,474 at issue,
the only evidence in the record about the purpose of any of those
checks is petitioner’s self-serving testimony as to 14 of them
and Mr. Guterman’s testimony as to 1 of those 14 checks. We are
not required to, and we shall not, rely on their testimony
regarding those checks.56 On the record before us, we find that
petitioner has failed to carry his burden of establishing that
during 1993 $27,474 of the deposits into petitioner’s accounts,
including payments against the balances due on petitioner’s
credit accounts and cash received in connection with certain of
those deposits, represented reimbursements from MZ Trading for
certain expenses that he had paid on its behalf.
Alleged Advances To Purchase Personal Items
Petitioner contends that the individuals shown below ad-
vanced him the following amounts that were part of the following
deposits, including the payment against the balance due on
55(...continued)
$27,474 at issue. We infer from petitioner’s failure to proffer
any such documentary evidence that any such evidence does not
exist and that, if it does exist, it would not have substantiated
petitioner’s position with respect to those deposits.
56With respect to the five checks from Mr. Guterman totaling
$2,112, petitioner testified that he never purchased anything for
Mr. Guterman. We presume that petitioner wants us to infer from
that testimony that the $2,112 in checks that he received during
1993 from Mr. Guterman represented reimbursements by Mr. Guterman
for certain expenses that petitioner had paid on behalf of MZ
Trading. Even if we had believed petitioner’s testimony that he
never purchased anything for Mr. Guterman, we would not draw any
such inference from any such testimony. In any event, we are not
required to, and we shall not, rely on petitioner’s testimony
that he never purchased anything for Mr. Guterman.
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