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for Mr. Reingatch’s daughter. In support of that contention,
petitioner relies on his self-serving testimony, on which we are
not required to, and we shall not, rely.58 On the record before
us, we find that petitioner has failed to satisfy his burden of
establishing that $119 of the March 19, 1991 deposit represented
an advance from Mr. Reingatch for the purchase of a walkman for
Mr. Reingatch’s daughter.
With respect to the August 22, 1991 deposit of $2,734,
petitioner contends that $1,224 of that deposit, which we have
found was derived from a $1,224 check from S&J Co., represented
an advance from Mr. Dubrovsky for the purchase at cost of a
television for Mr. Dubrovsky.59 In support of that contention,
petitioner relies on his self-serving testimony, on which we are
not required to, and we shall not, rely. On the record before
58The record contains no credible documentary evidence
showing that any portion of the Mar. 19, 1991 deposit of $20,119
was made with funds received from Mr. Reingatch or that peti-
tioner purchased a walkman for Mr. Reingatch’s daughter. We
infer that no such documentary evidence exists and that, if any
such evidence does exist, it would not have substantiated peti-
tioner’s claims regarding the alleged $119 advance in question.
59Although the record establishes that, during 1986 and as
of the time of the further trial in this case, Mr. Dubrovsky was
a part owner of S&J Co., the record does not disclose whether Mr.
Dubrovsky owned any part of that company on Aug. 22, 1991. We
note that, when questioned about the $1,224 check in question,
Mr. Dubrovsky did not remember any such check. The record
contains no credible documentary evidence showing that petitioner
purchased a television for Mr. Dubrovsky. We infer that no such
documentary evidence exists and that, if any such evidence does
exist, it would not have substantiated petitioner’s claim that
$1,224 of the Aug. 22, 1991 deposit of $2,734 represented an
advance from Mr. Dubrovsky for the purchase of a television for
Mr. Dubrovsky.
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