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Petitioner claims that none of the deposits into the Manila
Accounts during 1992, 1993, and 1994 were his income “except for
$36,000 to $38,000" from which he made intrabank transfers to his
personal account at Cullen Bank. Petitioner relies on his own
self-serving testimony to support this conclusion. Petitioner’s
testimony was questionable, vague, conclusory, and unsupported by
the evidence in the record. Under these circumstances, we are
not required to, and do not, rely on petitioner’s testimony to
sustain his burden of establishing error in respondent’s
determinations. Lerch v. Commissioner, 877 F.2d 624, 631-632
(7th Cir. 1989), affg. T.C. Memo. 1987-295; Tokarski v.
Commissioner, supra at 77.
Petitioner had dominion and control over the Manila
Accounts. Petitioner had the power to make withdrawals out of
the Manila Accounts. His Social Security number was the only one
on the Manila accounts, his name was on the Manila Accounts, he
was one of two signatories on the Manila accounts, and his
business address was on the Manila Accounts. Petitioner made
intrabank transfers into and out of the Manila Accounts and wired
money domestically and overseas from the Manila Accounts.
There is, however, documentary evidence suggesting that five
deposits into the Manila Accounts are not income to petitioner.
The revenue agent’s work papers were submitted as evidence. For
1993, the revenue agent listed as deposits into Cullen #226 a
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