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sented a business loan from Mr. Kroma. In support of that
contention, petitioner relies on (1) his self-serving testimony,
(2) a copy of the front side of the purchaser’s copy of a $20,000
Bank of America cashier’s check dated June 30, 1992, that peti-
tioner purchased and that was payable to Mr. Kroma, which peti-
tioner claims was a repayment of the alleged $50,000 loan, and
(3) a copy of the front side of a $1,250 check dated July 13,
1992, that was payable to Mr. Kroma, which petitioner contends
was a payment of 2 months’ interest on that alleged loan. We are
not required to, and we shall not, rely on petitioner’s testimony
regarding the alleged $50,000 loan from Mr. Kroma. Moreover, on
the instant record, we are not satisfied that Mr. Kroma42 re-
ceived the proceeds of the $20,000 Bank of America cashier’s
check dated June 30, 1992, and the $1,250 check dated July 13,
1992.43 That is because the record contains only the front sides
42We note that petitioner did not call Mr. Kroma as a wit-
ness with respect to the Mar. 23, 1992 deposit at issue. We
infer from petitioner’s failure to call Mr. Kroma that Mr.
Kroma’s testimony would not have been favorable to petitioner’s
position with respect to that deposit. We also note that peti-
tioner did not offer into evidence any credible documentary
evidence regarding the Mar. 23, 1992 deposit at issue. We infer
from petitioner’s failure to offer 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 with respect to the alleged loan from Mr. Kroma.
43Assuming arguendo that petitioner had established that Mr.
Kroma received the proceeds of the $20,000 Bank of America
cashier’s check dated June 30, 1992, and the $1,250 check dated
July 13, 1992, on the instant record, we find that petitioner has
failed to carry his burden of showing that the proceeds of those
two checks constituted a repayment of the alleged $50,000 loan in
question and 2 months’ interest on that alleged loan, respec-
(continued...)
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