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Mr. Reingatch deposited and/or cashed that check. For example,
Mr. Reingatch could have endorsed the check in question to
petitioner, who in turn deposited and/or cashed it. Nor are we
satisfied from the instant record what the purpose of the May 20,
1990 check was.
Assuming arguendo that we had found on the instant record
that Mr. Reingatch deposited and/or cashed the $20,000 check in
question, the only evidence in the record supporting petitioner’s
position that that check represented a loan to Mr. Reingatch is
petitioner’s self-serving testimony, on which we are not required
to, and we shall not, rely.75 On the record before us, we find
that petitioner has failed to carry his burden of establishing
that $20,000 of the March 19, 1991 deposit represented a repay-
ment by Mr. Reingatch of a loan that petitioner had made to him.
With respect to the September 7, 1993 deposit at issue of
$3,000, petitioner contends that that deposit, which we have
found was derived from a $3,000 check from Mr. Guterman, repre-
sented a repayment by Mr. Guterman of a loan that petitioner had
made to Mr. Guterman’s wife. In support of that contention,
petitioner relies on his self-serving testimony, on which we are
75Petitioner failed to offer into evidence any credible
documentary evidence showing that he lent $20,000 to Mr.
Reingatch in 1990 or at any other time prior to the date on which
petitioner claims Mr. Reingatch repaid that alleged loan. We
infer from petitioner’s failure to proffer any such documentary
evidence that any such evidence does not exist and that, if any
such evidence does exist, it would not have substantiated peti-
tioner’s position with respect to $20,000 of the Mar. 19, 1991
deposit at issue.
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