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us, we find that petitioner has failed to carry his burden of
establishing that $1,224 of the August 22, 1991 deposit repre-
sented an advance from Mr. Dubrovsky for the purchase of a
television on his behalf.
Alleged Rental Payments
Petitioner contends that the following deposits consisting
of payments against the balance due on petitioner’s equity line
account and the following cash that he received in connection
with one of those deposits, which we have found were derived from
two checks issued by First Marin Realty, Inc. (First Marin), are
not taxable.
Date of De- Payor of Amount
posit Item Deposited Amount of DepositNegotiated for Cash
6/1/93 First Marin $3,344 $70
6/11/93 First Marin 2,025 ---
According to petitioner, the two checks that First Marin
issued to him that were the source of the foregoing deposits and
cash represented rent paid on Mr. Reingatch’s house that peti-
tioner collected, pursuant to a power of attorney, on behalf of
Mr. Reingatch while Mr. Reingatch was out of the United States
and that petitioner used to make payments on Mr. Reingatch’s
mortgage loan. In support of those contentions, petitioner
relies on his self-serving testimony, on which we are not re-
quired to, and we shall not, rely.60 On the record before us, we
60Petitioner failed to offer into evidence any credible
documentary evidence to support his contentions regarding the
checks issued to him by First Marin, such as a power of attorney
from Mr. Reingatch authorizing petitioner to act on Mr.
(continued...)
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