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petitioner’s equity line account shown below:
Date of Amount of Al- Alleged Payor of
Deposit Account Total Deposit leged Advance Alleged Advance
3/11/91 Petitioner’s $2,515 $975 Mr. Dubrovsky
UVW account
3/19/91 Petitioner’s 20,119 119 Mr. Reingatch
equity line
account
8/22/91 Petitioner’s 2,734 1,224 Mr. Dubrovsky
UVW account
With respect to the March 11, 1991 deposit of $2,515,
petitioner contends that $975 of that deposit, which we have
found was derived from a $975 money order from Mr. Dubrovsky,
represented an advance from Mr. Dubrovsky for the purchase at
cost of a facsimile machine for Mr. Dubrovsky. In support of
that contention, petitioner relies on his self-serving testimony,
on which we are not required to, and we shall not, rely.57 On
the record before us, we find that petitioner has failed to carry
his burden of establishing that $975 of the March 11, 1991
deposit represented an advance from Mr. Dubrovsky for the pur-
chase of a facsimile machine on Mr. Dubrovsky’s behalf.
With respect to the March 19, 1991 deposit of $20,119,
petitioner contends that $119 of that deposit represented an
advance from Mr. Reingatch for the purchase at cost of a walkman
57We note that the record does not establish through credi-
ble documentary evidence that petitioner purchased a facsimile
machine for Mr. Dubrovsky. Furthermore, petitioner did not
question Mr. Dubrovsky about whether Mr. Dubrovsky had advanced
$975 to petitioner for the purchase of a facsimile machine. We
infer from petitioner’s failure to do so that any such testimony
would not have been favorable to petitioner’s position regarding
that alleged advance. In any event, we would not have been
required to rely on any of Mr. Dubrovsky’s testimony with respect
to the alleged $975 advance in question.
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