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promising to return it in 1 year with a guaranteed return, and
then went back to each individual several months later and
persuaded him or her to part with another substantial sum by
promising a quick return in 30 or 45 days. We draw the inference
that petitioner engineered a scheme with Jennifer R. that was
similar to the scheme to which John K. testified.
Unlike the situation with John K., Jennifer R. was deceased
at the time of trial and unable to give testimony from which we
might determine whether her payments to petitioner were loans or
entrustments of funds to invest. Regardless of which
characterization is more accurate, we are satisfied that
petitioner is taxable on the amounts Ms. R. turned over to her in
1990. We decline to accept petitioner’s self-serving testimony
regarding her dealings with Ms. R. Absent petitioner’s
testimony, there is no evidence that petitioner repaid the
amounts at issue when due or ever,10 and Ms. R. is now deceased.
10 To support her claim that she made repayment to Jennifer
R., petitioner offered into evidence two deposit slips dated in
January 1991 evidencing deposits totaling $2,771 into an account
in the name of Jennson Co. The exhibits were not admitted
because their relevance to Jennifer R. was not established. As
part of her posttrial brief, petitioner submitted a copy of a
business certificate indicating that Jennifer R. was conducting
business under the name Jennson Co. Even if the foregoing
exhibits were admitted, however, they would not establish
repayment because there is no proof that petitioner made the
deposits or, even if petitioner made them, that the deposits
represented repayments with respect to the $15,000 in issue-–as
opposed to, e.g., payments to Jennifer R. for rendering escort
services pursuant to petitioner’s arrangements.
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