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Syelsky canceled his order for the merchandise in question and
asked petitioner to return the $30,000. Thereafter, Mr. Vulis,
as the guarantor of Mr. Syelsky’s $30,000 loan, repaid that loan.
Around December 15, 1992, Mr. Syelsky gave petitioner a
$20,000 check that Mr. Syelsky signed and that represented a
personal loan by Mr. Syelsky to petitioner. On that date, the
proceeds of that $20,000 check were used to make a payment
against the balance due on petitioner’s equity line account.
M.P. Electronics
At certain times during 1991 and 1992, petitioner conducted
certain business transactions with M.P. Electronics, a business
operated by Hardit Chaudry (Mr. Chaudry) and Kishore Raja (Mr.
Raja). At those times, M.P. Electronics engaged in the purchase
for resale of various types of merchandise from retail stores,
such as Circuit City, Macy’s, and Good Guys (retail stores),
which were overstocked, defective, damaged, and/or otherwise not
salable by such stores. (We shall refer collectively to the
types of merchandise that M.P. Electronics purchased from certain
retail stores as nonsalable merchandise.) Generally, at those
times, petitioner and M.P. Electronics jointly placed bids with
certain retail stores for the purchase of certain of such stores’
nonsalable merchandise.
On the dates shown below, the following checks were drawn on
petitioner’s UVW account and made payable to M.P. Electronics or
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