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conceded that he is taxable on $1,000 of that deposit and that
that concession, taken together with respondent’s concession of
$16,700 of that deposit, leaves no portion of the September 14,
1993 alleged MZ Trading-related deposit that remains at issue in
this case.74
Alleged Repayments of Loans
Petitioner contends that $20,000 of the March 19, 1991
deposit of $20,119 and the entire September 7, 1993 deposit at
issue of $3,000 represented repayments of certain loans that he
had made to certain individuals.
With respect to the March 19, 1991 deposit of $20,119,
petitioner contends that $20,000 of that deposit constituted a
repayment by Mr. Reingatch of a loan that petitioner had made to
him. In support of that contention, petitioner relies on his
self-serving testimony, on which we are not required to, and we
shall not, rely. Petitioner also relies on a copy of the front
side of a $20,000 check dated May 20, 1990, that was signed by
petitioner and payable to Mr. Reingatch. Petitioner claims that
that check represented the $20,000 that he lent Mr. Reingatch.
Although we are satisfied from the copy of the front side of the
May 20, 1990 check on which petitioner relies that that check was
negotiated, we are not satisfied from that copy, inter alia, that
74Even if we had not concluded that, prior to the trial in
this case, petitioner conceded $1,000 of the Sept. 14, 1993
alleged MZ Trading-related deposit, on the instant record, we
find that petitioner has failed to carry his burden of establish-
ing that $1,000 of that deposit is not taxable to him.
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