Katrina L. Price - Page 12




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          Washington, 459 F. Supp. 1020, 1095 (W.D. Wash. 1978).  There is            
          no evidence to support petitioner’s contention.  Petitioner did             
          not testify that the photo shop charged expenses on her credit              
          cards, and her claim after trial that the photo shop charged its            
          expenses on her credit cards is reason to disbelieve her trial              
          testimony.                                                                  
               Another reason for disbelieving petitioner’s trial testimony           
          is the fact that she said in her answering brief that we should             
          disregard her trial testimony relating to her photo store salary.           
          It is not clear what parts of petitioner’s testimony we should              
          believe under these circumstances.                                          
               Petitioner contends that some of the money that she                    
          deposited was her own money that she had withdrawn for gambling             
          and redeposited afterwards.  Petitioner’s testimony in this                 
          regard was very general.  She provided us no basis to decide                
          which of the bank deposits were redeposits of money she had                 
          withdrawn.                                                                  
               We conclude that, in addition to the $13,000 salary that               
          petitioner earned each year from the photo store, petitioner had            
          unreported income of $25,500 for 1993 and $5,486 for 1994.                  
          C.   Whether Petitioner Is Liable for the Addition to Tax for               
               Failure To File Her 1993 Income Tax Return                             
               Respondent determined that petitioner is liable for the                
          addition to tax under section 6651(a) for failure to file a                 







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