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We conclude that these five checks--totaling $36,000 for
1993 and $1,503 for 1994--are not income to petitioner; however,
we conclude that the remaining deposits into the Manila Accounts
in 1992, 1993, and 1994 are petitioner’s income.
B. Nations Trust Account
Petitioner claims that $98,550 of the $100,000 deposit into
the Nations trust account in 1993 is not unreported income.7
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,
supra at 631-632; Tokarski v. Commissioner, 87 T.C. at 77.
Petitioner stipulated that the deposits into the Nations
trust account in 1994 were income to him. Petitioner also
testified that he used his attorney trust accounts as personal
accounts.
Petitioner originally claimed that the $100,000 deposit into
the Nations trust account was a certificate of deposit belonging
to a purported client of his named Charter Trading Corp., owned
by William C. Comey. After learning that the $100,000 deposit
7 Petitioner concedes that $1,450 of the $100,000 deposit
is his income.
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