- 83 -
Tokarski v. Commissioner, 87 T.C. at 77.34 As for the checks
that petitioner claims represented repayments by him to Mr.
Dubrovsky of the alleged $10,000 loan, on the instant record, we
find that petitioner has failed to carry his burden of showing
the purpose of those checks.35 On the record before us, we find
that petitioner has failed to carry his burden of establishing
that $10,000 of the February 12, 1991 deposit in question repre-
sented a personal loan from Mr. Dubrovsky.
With respect to the April 30, 1992 deposit at issue of
$15,000, petitioner contends that that deposit, which we have
found was derived from a $15,000 cashier’s check issued by Great
Western Bank, represented a personal loan from Mr. Ferrer. In
support of his contention that Mr. Ferrer’s funds were used to
purchase that cashier’s check, petitioner relies on his self-
serving testimony, on which we are not required to, and we shall
34The principle that we are not required to rely on testi-
mony, even if uncontradicted, that we find to be, inter alia, not
credible, questionable, unreasonable, general, and/or vague is so
well established that hereinafter we shall not cite the case law
supporting that principle.
35Petitioner could have issued those checks, which total
$9,525, to Mr. Dubrovsky for purposes other than as repayments of
the alleged $10,000 loan. In this connection, petitioner failed
to offer into evidence any credible documentary evidence to
establish that $10,000 of the Feb. 12, 1991 deposit in question
represented a personal loan from Mr. Dubrovsky and Ms. Dubrovsky
and that the checks from petitioner to Mr. Dubrovsky on which
petitioner relies represented repayments of the alleged $10,000
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 substan-
tiated petitioner’s position with respect to $10,000 of the Feb.
12, 1991 deposit in question.
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