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these expenditures.37 Additionally, some of the copies of checks
that petitioner provided are made payable to “cash” for
significant sums of money.38
Petitioner also alleges that he purchased vehicles for the
benefit of Alviso and GMT with his personal funds for which he
was not reimbursed. However, he fails to provide copies of the
titles or any documentation which would demonstrate in whose
names the alleged vehicles were purchased.
Petitioner provides no evidence that he advanced/lent
substantial amounts of money to Alviso or GMT except copies of
canceled checks and his trial testimony.39 No payee testified as
to these expenditures. There is no evidence of a repayment
schedule, maturity date, special rights and duties of the
parties, written memorialization of the debtor-creditor
relationship, etc. On this record, we find that petitioner
37On brief, petitioner concedes that, to the extent he does
not know the purpose for the expenditure, he is not now arguing
that such expenditure is an adjustment to reconstructed income.
38For example, check No. 109 dated Mar. 20, 1990, for
$9,645; check No. 112 dated Apr. 17, 1990, for $9,741.50; check
No. 119 dated Apr. 30, 1990, for $9,847.00; check No. 118 dated
Apr. 27, 1990, for $8,697.50; and check No. 117 dated Apr. 24,
1990, for $9,750.00. Despite providing the Court with copies of
the aforesaid checks, petitioner is now not claiming these checks
represent either advances or any other deductible business
expense.
39The record indicates that petitioner did not make any such
advances to Alviso or GMT. The balance sheets included with
their 1990, 1991, and 1992 returns list “Loans from Stockholders”
as $0.
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