- 93 - CIAL INVOICE” dated July 11, 1992, that shows “AMUKE Group of Companies” under the heading “Importer/Exporter” and the sale of, inter alia, 12,144 “Lighters” for $24,288, and (3) a copy of the front side of the purchaser’s copy of a $16,000 Bank of America cashier’s check dated July 20, 1992, that was payable to Carvis Discount. We are not required to, and we shall not, rely on the testimony of petitioner regarding the alleged $26,250 business loan.46 Moreover, we find that the document entitled “COMMERCIAL INVOICE” does not show (1) that petitioner (or UVW) was involved in the purchase of the lighters reflected in that document and (2) that Amuke Business Association lent money to petitioner to purchase such lighters. Nor do we find that the copy of the front side of the purchaser’s copy of the $16,000 Bank of America cashier’s check dated July 20, 1992, that was payable to Carvis Discount,47 establishes petitioner’s position with respect to the 46We note that Mr. Vulis testified that he had no recollec- tion of the purpose of the $26,250 check from Amuke Business Association to petitioner. We also note that petitioner did not offer into evidence any credible documentary evidence showing that the $26,250 check from Amuke Business Association repre- sented a business loan from that 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 with respect to that alleged loan. 47We are not satisfied from that copy, inter alia, that Carvis Discount deposited and/or cashed the $16,000 Bank of America cashier’s check payable to it dated July 20, 1992. For example, Carvis Discount could have endorsed that cashier’s check to petitioner, who in turn deposited and/or cashed it. In this regard, as noted above, the record shows that on Apr. 28, 1992, petitioner deposited into petitioner’s UVW account a $12,000 Bank of America cashier’s check that was payable to Marcel Feldberg. (continued...)Page: Previous 83 84 85 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 Next
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