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that year not challenged by respondent. The loan schedule
provides for an interest rate of 7 percent and shows that
petitioner purportedly repaid some of the debt in a later year.
We believe petitioner has proven that he borrowed $1,904 and
$15,000 from Taxman in 1992. Therefore, these amounts were not
income to petitioner in 1992.
Respondent also determined in the notice of deficiency that
petitioner was required to include in income the balance of WRP’s
money market account ($10,931) that he withdrew in April 1992.
The parties stipulated that the $10,000 given to petitioner by
Ms. Garceau was not used for real estate investments as Ms.
Garceau intended. As we understand petitioner’s argument, he
asserts that in 1995, he repaid Ms. Garceau the $10,000 plus 8
percent interest, borrowing the funds necessary to do so from
WFIC. He claims a promissory note in the record for $13,674.35
(which approximately equals $10,000 plus 8 percent interest,
compounding annually over 5 years) evidences the transaction.
However, petitioner has not shown that he actually repaid Ms.
Garceau or WRP. The record does not contain petitioner’s or
WFIC’s bank statements for 1995, and we cannot verify that
$13,674.35 was withdrawn from either of them. Ms. Garceau did
not testify, and petitioner’s testimony on this matter was
unsupported by the record. In addition, the purported debt for
$13,674.35 is not reflected on WFIC’s 1992 loan schedule or
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