- 11 -
percent of his earnings from the time he was 15 years old.
Petitioner also told Hensley that he worked odd jobs, that he had
some savings from tobacco sales from his family's farm, and that
he and his wife had received a $5,000 wedding gift from Sandra's
grandfather.
Upon reviewing petitioner's bank records during the course
of the interview, Hensley discovered that, in addition to
purchasing the Corvette for cash, petitioner had made at least
$50,000 in cash deposits into a bank account in 1989 and 1990.
Petitioner and Hensley spent the rest of the day going over his
records and discussing where he obtained the money to make such
deposits. After Hensley perceived some inconsistencies between
the records and what petitioner had told her, and because she was
having trouble understanding petitioner, she asked petitioner to
provide her with a written statement explaining the
discrepancies, to which he assented. Petitioner prepared the
written statement after he and Hensley had discussed the fact
that gifts of up to $10,000 per donee were tax-free to the donor.
The written statement was not made under oath, and petitioner's
signature does not appear on it. The written statement provided
as follows:
Cash gifts:
Parents Grandparent
starting at approximately age 15 basically yearly in
area of [$]5,000-10,000 (an estimate) yearly sometimes
it varied from year to year--not in lump sum but over
period of time. Could be for example: allowances,
given on holidays and birthdays etc. * * *
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