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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 he
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