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find that petitioner has failed to carry his burden of establish-
ing that the June 1, 1993 transaction at issue and the June 11,
1993 deposit at issue represented rent on Mr. Reingatch’s house
that petitioner used to pay Mr. Reingatch’s mortgage loan.
Alleged Items of MZ Trading
Petitioner contends that the following deposits consisting
of payments during 1993 against the balance due on petitioner’s
equity line account represented certain gross receipts of MZ
Trading that MZ Trading had reported in its Form 1065 for 1993,
certain loans to MZ Trading, or a reimbursement with respect to a
transaction of MZ Trading:
Date of Deposit Amount of Deposit Payor
2/10/93 $23,891 Commonwealth Enterprises
4/26/93 22,500 Mr. Vulis
4/26/93 77,580 East-West
5/3/93 37,680 Mr. Vulis
5/3/93 30,000 East-West
5/12/93 41,950 East-West
7/9/93 6,450 Commonwealth Enterprises
8/30/93 22,000 East-West
9/14/93 117,700 Mr. Kirdan
1Prior to the trial in this case, respondent conceded that $16,700 of
the $17,700 deposit is not taxable to petitioner.
(We shall sometimes refer to the foregoing deposits as alleged MZ
Trading-related deposits.)
60(...continued)
Reingatch’s behalf with respect to Mr. Reingatch’s funds and
canceled checks showing that petitioner made any payments on Mr.
Reingatch’s mortgage loan. 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 substan-
tiated petitioner’s position with respect to the two checks
issued to him by First Marin.
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