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alleged $26,250 business loan from Amuke Business Association.
On the record before us, we find that petitioner has failed to
carry his burden of establishing that the June 30, 1992 transac-
tion at issue represented a business loan from Amuke Business
Association.
With respect to the August 7, 1992 transaction at issue
consisting of a $7,720 deposit and $150 in cash that petitioner
received, petitioner contends that that deposit and that cash,
which we have found were derived from a $7,870 check from Amuke
Group, represented a business loan from that organization for the
purchase of certain candy. In support of that contention,
petitioner relies on his self-serving testimony, on which we are
not required to, and we shall not, rely.48 On the record before
47(...continued)
Assuming arguendo that the record had established that
Carvis Discount deposited and/or cashed the $16,000 Bank of
America cashier’s check payable to it, on that record, we find
that petitioner has failed to carry his burden of establishing
that Carvis Discount received the proceeds of that check in
connection with the purchase of certain cigarette lighters with
respect to which Amuke Business Association allegedly lent
petitioner $26,250.
48We note that petitioner failed to elicit from Mr. Vulis,
who at all relevant times was involved in the operations of Amuke
Group, any testimony with respect to the alleged $7,870 loan from
Amuke Group. We infer from petitioner’s failure to elicit any
such testimony that any such testimony would not have been
favorable to petitioner’s position regarding that alleged loan.
We also note that petitioner did not offer into evidence any
credible documentary evidence supporting his position regarding
the alleged $7,870 loan from Amuke Group. We infer from peti-
tioner’s failure to proffer any such documentary evidence that
any such documentary evidence does not exist and that, if any
such evidence does exist, it would not have substantiated peti-
tioner’s position with respect to that alleged loan.
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