Steven H. Toushin - Page 5

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          Company, Real Estate Management, Gold Distribution Company, and             
          Walter Killeen Company.7                                                    
               In addition to the various Oak Trust accounts, petitioner              
          was signatory on a checking account in the name of Anthony J.               
          Medina, Jr. Co. at Northern Trust Company in Chicago and for part           
          of the year 1982 had signature authority on a checking account in           
          the name of Toushin & Company at Chemical Bank in New York City.8           
          Petitioner's Cash Transactions                                              
               On his individual Federal income tax return, Form 1040,                
          filed for the year 1982, petitioner reported income from wages,             
          capital gains from the sale of films, and rental income.9  During           
          1982, E & A of Illinois loaned $11,110 in cash to petitioner.               
          The parties have stipulated that "petitioner wrote no checks to             
          cash" during 1982, cashed no salary checks during that year, and            
          "received no cash back on deposits" in 1982.                                
               Despite the apparent paucity of sources of cash, during the            
          year 1982 petitioner came into possession of relatively large               
          amounts of currency.  He deposited $3,260 in cash into his                  


          7The parties have stipulated copies of various bank records                 
          as exhibits associated with these respective checking accounts.             
          8The parties have stipulated copies of various bank records                 
          as exhibits associated with these respective checking accounts.             
          9We have determined from the stipulation that petitioner's                  
          wages were paid by check.  Since petitioner has raised no                   
          argument to the contrary, for purposes of this motion, we will              
          assume that the other income items reported on the return were              
          also paid by check.                                                         




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