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us, we find that petitioner has failed to carry his burden of
establishing that the August 7, 1992 transaction at issue repre-
sented a business loan from Amuke Group.
With respect to the September 11, 1992 deposit at issue of
$3,850, petitioner contends that that deposit, which we have
found was derived from a $3,850 check from Commonwealth Enter-
prises, represented a business loan from Mr. Vulis. In support
of that contention, petitioner relies on Mr. Vulis’ general and
conclusory testimony regarding the general business practice
between Commonwealth Enterprises and petitioner, namely, gener-
ally Commonwealth Enterprises advanced petitioner the funds
needed for petitioner to purchase merchandise that he had located
on its behalf and that it wanted to acquire for resale. We are
not persuaded by that testimony of Mr. Vulis on which petitioner
relies that the $3,850 check from Commonwealth Enterprises
represented a business loan from Mr. Vulis.49 On the record
before us, we find that petitioner has failed to establish that
the September 11, 1992 deposit at issue represented a business
loan from Commonwealth Enterprises.
49We note that petitioner failed to question Mr. Vulis
specifically with respect to the alleged $3,850 loan at issue.
We infer from petitioner’s failure to elicit any such testimony
that any such testimony would not have been favorable to peti-
tioner’s position regarding that alleged loan. We also note that
petitioner failed to introduce any credible documentary evidence
showing that the $3,850 check from Commonwealth Enterprises
represented a business loan from Mr. Vulis. We infer from
petitioner’s failure to offer 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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