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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...)
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