- 46 -
the taxpayer to some tax-generating activity. Id.; Schad v.
Commissioner, 87 T.C. 609, 620 (1986), affd. without published
opinion 827 F.2d 774 (11th Cir. 1987). The record here clearly
links petitioners to the unreported income. Polymer and Chemical
Traders had no business purpose. Petitioner controlled the
Polymer and Chemical Traders accounts. We conclude that
petitioner controlled Polymer because he caused Resyn to pay
Polymer for fictitious sales, he had Levenson sign blank Polymer
checks, and he withdrew substantial amounts of cash from the
Polymer account. We conclude that petitioner controlled Chemical
Traders because he concealed it and its bank account from his
accountants and bookkeepers, he withdrew substantial amounts of
cash from the account, and he used funds from the account to buy
stock. Resyn paid petitioner's personal expenses directly.
Petitioner paid at least $428,382 for personal stock investments
with funds from Chemical Traders. Petitioner withdrew cash from
the Polymer and Chemical Traders accounts. Records do not exist
showing how petitioner used all of the funds that he diverted
from Resyn to the Polymer and Chemical Traders accounts.
Petitioners contend that respondent's determination should
not be presumed to be correct because respondent did not consider
the possibility that petitioner replaced money he had previously
taken from his brokerage accounts and because respondent did not
analyze petitioners' net worth. We know of no requirement and
petitioners cite none that respondent must conduct a net worth
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