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Date Description Payee Amount
8/27/91 Check drawn on petitioner’s UVW ac-Fashions store $212
count
8/28/91 Check drawn on petitioner’s UVW ac-Fashions store 584
count
9/2/91 Check drawn on petitioner’s UVW ac-Fashions store 1,100
count
9/5/91 Check drawn on petitioner’s UVW ac-Fashions store 334
count
12/17/91 Bank of America cashier’s check Circuit City 9,900
2/10/92 Charge on acct. Carvis Discount2,134
No. 5273-0298-0010-0917
3/2/92 Charge on acct. Carvis Discount2,550
No. 5273-0298-0010-0917
3/3/92 Bank of America cashier’s checkMacy’s California 10,000
4/15/92 Check drawn on petitioner’s UVW ac- Cash 12,000
count
4/21/92 Bank of America cashier’s checkM.P. Electronics11,400
4/22/92 Check drawn on petitioner’s UVW ac-M.P. Electronics 5,000
count
5/18/92 Bank of America cashier’s checkMacy’s California 14,000
In support of petitioner’s contention regarding the forego-
ing items, petitioner relies on his self-serving testimony, on
which we are not required to, and we shall not, rely. Petitioner
also relies on the testimony of Mr. Raja.78 Based on the Court’s
evaluation of Mr. Raja’s testimony, we are not required to, and
we shall not, rely on his testimony regarding the items listed
above. We found Mr. Raja’s testimony to have been based largely
on his general business practices with petitioner, as opposed to
78Petitioner failed to offer into evidence any credible
documentary evidence, such as receipts, invoices, or any other
credible business records of UVW, that establishes petitioner’s
position regarding the claimed cost of goods sold at issue for
1991 and 1992. 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 regarding that claimed cost of goods sold.
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