- 96 - With respect to the September 23, 1992 transaction at issue consisting of a $30,000 deposit and $375 in cash that petitioner received, petitioner contends that that deposit and that cash, which we have found were derived from a $30,375 check from Amuke Group, represented a business loan from that organization for the purchase of certain water filters. In support of that conten- tion, petitioner relies on the testimony of Mr. Vulis. Mr. Vulis identified the $30,375 check from Amuke Group and testified that that check represented a loan to petitioner for the purchase of water filters. We found that testimony of Mr. Vulis to be credible. On the record before us, we find that petitioner has satisfied his burden of showing that the September 23, 1992 transaction at issue represented a business loan from Amuke Group. With respect to the December 15, 1992 deposit in question of $30,100, petitioner contends that $30,000 of that deposit, which we have found was derived from a $30,000 check from Mr. Syelsky, represented a business loan from Mr. Syelsky. In support of that contention, petitioner relies on his self-serving testimony and the testimony of Mr. Syelsky and of Mr. Vulis. We are not required to, and we shall not, rely on petitioner’s testimony regarding the $30,000 alleged loan. Mr. Syelsky testified that the $30,000 check that he issued to petitioner constituted a business loan, which Mr. Vulis guarantied and the proceeds of which petitioner was to use to purchase certain candy on behalf of Mr. Syelsky. Mr. Syelsky further testified that, after hePage: Previous 86 87 88 89 90 91 92 93 94 95 96 97 98 99 100 101 102 103 104 105 Next
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