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Trading’s purported 1993 transaction summary, entries appeared
under columns headed “cost”, “sold”, “profit”, and “expenses”.
Numbers and handwriting that is largely illegible appeared in
that purported summary under each of those columns. We are not
satisfied that MZ Trading’s purported 1993 transaction summary is
a credible document reflecting transactions in which MZ Trading
engaged during 1993. At trial, we admitted MZ Trading’s pur-
ported 1993 transaction summary into the record solely for the
limited purpose that it was a document which showed what the
preparers of that document claimed to be transactions of MZ
Trading during 1993. Based on the Court’s evaluation of MZ
Trading’s purported 1993 transaction summary, including the
Court’s evaluation of the testimony of petitioner and of Mr.
Guterman, both of whom prepared most, if not all, of that pur-
ported summary and both of whom we did not find to be credible,
we are not required to, and we shall not, rely on it.
With respect to petitioner’s reliance on Mr. Oliveras’
summary of MZ Trading’s deposits during 1993 in support of his
position regarding the alleged MZ Trading-related deposits, as we
stated above, even if we were to have admitted that summary into
the record for the truth of its content, it does not establish
petitioner’s claim that certain of MZ Trading’s gross receipts
for 1993, which it reported in its Form 1065 for 1993 and which
petitioner claims were not deposited during that year into MZ
Trading’s bank account, were deposited into petitioner’s equity
line account.
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