- 18 - represented both Mr. and Mrs. Walker from March 19, 1990 through April 14, 1993, ceased his representation of them pursuant to leave of this Court, and then resumed being counsel solely to Mrs. Walker on February 3, 1994. On August 30, 1990, Mr. and Mrs. Walker filed a motion to suppress all evidence obtained from grand jury materials. This Court denied their motion on February 5, 1992. See Walker v. Commissioner, T.C. Memo. 1992-54. Sometime in October 1993, during the course of pretrial discovery conducted by respondent, Mr. and Mrs. Walker for the first time asserted that Mrs. Walker had not signed the 1978, 1979, 1980, and 1981 returns. In their responses to certain other interrogatories served upon them by respondent, they also denied that, during or after the years in issue, Mr. Walker (1) transferred any assets of over $500 (other than for certain automobiles) to Mrs. Walker; and (2) made any gifts to her. OPINION Mr. Walker's Unreported Taxable Income The parties agree that, during 1978 through 1981, Mr. Walker diverted and received from West Jersey the funds determined in our findings. They also agree that these diverted funds, less amounts Mr. Walker used in purchasing cashier checks for Simmel and the boat for Short, represent unreported taxable income of Mr. Walker for 1978, 1979, 1980, and 1981, except to the extent of additional cash payments that Mr. Walker can establish were made by him "to (or for the direct benefit of)" Short and SimmelPage: Previous 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 Next
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