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With respect to the July 9, 1993 alleged MZ Trading-related
deposit at issue of $6,450, petitioner contends that that de-
posit, which we have found was derived from a $6,450 check from
Commonwealth Enterprises, represented “a reimbursement for the
shipping of candies to Mr. Ivenin relating to MZ Trading trade
number 6" reflected in MZ Trading’s purported 1993 transaction
summary.70 In support of that contention, petitioner relies on
his self-serving testimony, on which we are not required to, and
we shall not, rely.71 On the record before us, we find that
70The nature of the alleged transaction number 6 reflected
in MZ Trading’s purported 1993 transaction summary is not legi-
ble.
71Petitioner failed to offer into evidence any credible
documentary evidence regarding the July 9, 1993 alleged MZ
Trading-related deposit at issue. 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 substantiated petitioner’s position with respect to that
deposit.
Petitioner questioned Mr. Vulis about the $6,450 check from
Commonwealth Enterprises that was the source of the July 9, 1993
alleged MZ Trading-related deposit at issue. Mr. Vulis testified
as follows with respect to that check:
A * * * It’s a check drawn on Commonwealth Enter-
prise [sic] checkbook. I have very bad copy, but
it’s for $6,450, I guess.
Q And was payable to whom?
A To Mr. Brodsky.
Q For what purpose?
A Well, as far as I can recall, looking at that
check, it says J.B., 25 percent 25,000, which
means jelly-beans, 25 percent out of $25,000.
(continued...)
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