- 39 - petitioner’s 1987 return has no relevance to business expenses of the sole proprietorship in 1982, 1983, and 1984, because any business expenses taken as deductions for those years were incurred before Taxman existed. In addition, we concluded above that the record does not support that Taxman assumed any liabilities other than two bank loans. Therefore, petitioner had income of $310 in 1990 from Taxman’s payment for petitioner’s personal legal expenses. In 1990, Taxman also repaid a bank loan for $2,000, plus interest of $147, that had been obtained in petitioner’s name in July 1989. Petitioner claims that he obtained the loan in his own name because Taxman had reached the limit of its line of credit with the bank. Petitioner testified that he deposited the funds into WFIC’s account, and WFIC used the funds until it received its tax refund in 1990. The 1989 bank statements for WFIC, Taxman, and petitioner are not part of the record. Petitioner offered no evidence that Taxman’s credit limit had been reached or that the loan funds were deposited into WFIC’s bank account. We give little weight to petitioner’s testimony on this matter given that he claimed Taxman had reached the limit of its line of credit but WFIC used the funds and repaid the loan. We do not believe petitioner has met his burden of proving the $2,147 was not repaid on his behalfPage: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 Next
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