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1. Whether, and to what extent, amounts that petitioners
deposited into their print shop bank accounts are includable in
their 1986, 1987 and 1988 gross income. We hold petitioners must
include $449,306, $401,226, and $332,147 in gross income for
their 1986, 1987, and 1988 taxable years, respectively.
2. Whether respondent is barred from assessing tax for
petitioners' 1988 taxable year. We hold she is not.
3. Whether petitioners are liable for additions to tax
under section 6651(a)(1) for their 1986, 1987, and 1988 taxable
years. We hold they are.
4. Whether petitioners are liable for additions to tax
under section 6653(a)(1)(A) and (B) for their 1986 and 1987
taxable years, and under section 6653(a)(1) for their 1988
taxable year. We hold they are.
Unless otherwise indicated, section references are to the
Internal Revenue Code applicable to the years in issue. Rule
references are to the Tax Court Rules of Practice and Procedure.
Dollar amounts are rounded to the nearest dollar.
FINDINGS OF FACT1
1 During the trial, petitioners' counsel presented testimony
of petitioners and their acquaintances. We found much of their
testimony to be vague, elusive, and uncorroborated. Under the
circumstances, we are not required to, and we do not, rely on
that testimony to support petitioners' positions. See Ruark v.
Commissioner, 449 F.2d 311, 312 (9th Cir. 1971), affg. per curiam
T.C. Memo. 1969-48; Clark v. Commissioner, 266 F.2d 698, 708-709
(9th Cir. 1959), affg. in part and remanding T.C. Memo. 1957-129.
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