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issued the $30,000 check to petitioner, he canceled his order for
the candy in question and requested petitioner to repay the
$30,000 loan. According to Mr. Syelsky, because petitioner did
not have the money with which to repay that loan, Mr. Vulis
repaid it pursuant to Mr. Vulis’ guaranty of that loan. Mr.
Vulis confirmed during his testimony at the further trial that he
paid $30,000 to Mr. Syelsky on petitioner’s behalf. We found the
testimony of Mr. Syelsky and of Mr. Vulis with respect to the
alleged $30,000 business loan from Mr. Syelsky to petitioner to
be credible. On the record before us, we find that the peti-
tioner has satisfied his burden of establishing that $30,000 of
the December 15, 1992 deposit in question represented a business
loan from Mr. Syelsky.
With respect to the December 16, 1992 deposit at issue of
$10,500, petitioner contends that that deposit, which we have
found was derived from a $10,500 check from Commonwealth Enter-
prises, represented a business loan from Commonwealth Enterprises
for the purchase of certain unspecified merchandise. In support
of that contention, petitioner relies on the general and
conclusory testimony of Mr. Vulis with respect to the general
business practice of Commonwealth Enterprises and petitioner,
namely, generally 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 $10,500 check from Commonwealth
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