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Association that he later repaid. In support of that contention,
petitioner relies on his self-serving testimony, on which we are
not required to, and we shall not, rely.37 On the record before
us, we find that petitioner has failed to carry his burden of
establishing that the June 26, 1992 deposit at issue represented
a personal loan from Amuke Business Association.
With respect to the August 28, 1992 deposit at issue of
$15,896, petitioner contends that $3,000 of that deposit, which
we have found was derived from a $3,000 check from Commonwealth
Enterprises dated August 27, 1992, represented a personal loan
from Mr. Averbach who, along with Mr. Ferrer, participated with
Mr. Vulis in operating Amuke Group. In support of that conten-
tion, petitioner relies on his self-serving testimony, on which
we are not required to, and we shall not, rely.38 On the record
37We note that, when questioned about the two checks total-
ing $7,000 from Amuke Business Association to petitioner, Mr.
Vulis, who at all relevant times was familiar with the activities
of that association, was unable to recall the purpose for which
Amuke Business Association issued those checks.
Petitioner failed to offer into evidence any credible
documentary evidence regarding the alleged $7,000 loan from Amuke
Business Association. 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 petitioner’s position regarding that alleged
loan.
38We note that petitioner did not call Mr. Averbach as a
witness and did not elicit any testimony from Mr. Vulis, who at
all relevant times was associated with Commonwealth Enterprises,
with respect to the purpose for which Commonwealth Enterprises
issued the $3,000 check to petitioner. Nor did petitioner offer
into evidence any credible documentary evidence regarding the
(continued...)
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