- 82 -
Date of Total Amount of
Deposit Account Deposit Alleged Loan Alleged Lender
2/12/91 Petitioner’s UVW $14,195 $10,000 Mr. Dubrovsky and
account Ms. Dubrovsky
4/30/92 Petitioner’s equity15,000 15,000 Mr. Ferrer
line account
6/26/92 Petitioner’s equity7,000 7,000 Amuke Business
line account Association
8/28/92 Petitioner’s UVW 15,896 3,000 Mr. Averbach
account
12/15/92 Petitioner’s equity20,000 20,000 Mr. Syelsky
line account
5/25/93 Petitioner’s equity30,000 30,000 Roman Kirdan
line account
With respect to the February 12, 1991 deposit in question of
$14,195, petitioner contends that $10,000 of that deposit, which
we have found was derived from a $10,000 check from Mr. Dubrovsky
and Ms. Dubrovsky,32 represented a personal loan to him. In
support of that contention, petitioner relies on his self-serving
testimony, Mr. Dubrovsky’s testimony, and certain checks from
petitioner to Mr. Dubrovsky that petitioner contends represented
repayments of the alleged $10,000 loan.33 Based on the Court’s
evaluation of the testimony of petitioner and of Mr. Dubrovsky,
we are not required to, and we shall not, rely on their testimony
regarding the February 12, 1991 deposit in question. See Lerch
v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989), affg.
T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688, 689-
690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;
32Although petitioner claims that the $10,000 check in
question was from Mr. Dubrovsky, the record shows that the payors
of that check were Mr. Dubrovsky and Ms. Dubrovsky.
33We note that the various checks that petitioner contends
represented repayments of the alleged $10,000 loan total $9,525.
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