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Enterprises represented a business loan from Commonwealth Enter-
prises.50 On the record before us, we find that petitioner has
failed to carry his burden of establishing that the December 16,
1992 deposit at issue represented a business loan from Common-
wealth Enterprises.
With respect to the January 14, 1993 deposit of $5,000,
petitioner contends that that deposit, which we have found was
derived from a $5,000 check from Amuke Group, represented a
business loan from Amuke Group for the purchase of certain
cordless telephones. Petitioner failed to raise as an issue in
petitioner’s further trial memorandum that the January 14, 1993
deposit in question represented a business loan from Amuke Group.
Accordingly, pursuant to the Court’s March 31, 2000 Order, we
shall not address that matter.51
50We note that petitioner failed to question Mr. Vulis
specifically with respect to the alleged $10,500 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 offer into evidence any credible documentary
evidence showing that the $10,500 from Commonwealth Enterprises
represented a business loan from that company. We infer from
petitioner’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
petitioner’s position with respect to that alleged loan.
51Assuming arguendo that petitioner’s further trial memoran-
dum had raised as an issue that the Jan. 14, 1993 deposit repre-
sented a business loan from Amuke Group, we find on the record
before us that petitioner has failed to establish that that
deposit constituted a business loan from that organization. To
support his position on that matter, petitioner relies on his
self-serving testimony, on which we are not required to, and we
shall not, rely. We note that petitioner did not elicit any
(continued...)
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