- 11 - interaccount transfers from the sum of the $823,673 in total bank deposits and $21 in unreported interest during 1987. Respondent further determined that petitioners received and failed to report gross income totaling $332,147 during their 1988 taxable year. She determined this amount by deducting $150,044 in gross receipts reported, $14,419 in ISF checks, and $32,657 in interaccount transfers from the sum of the $529,258 in total bank deposits and $9 in unreported interest during their 1988 taxable year. Mr. Ghadiri claimed that he received approximately $680,000 in loans during the years in question. However, his allegation was unsupported by documentary evidence, and we found this uncorroborated testimony unpersuasive. Mr. Ghadiri testified that acquaintances made loans to him during the years in question. Although Mr. Ghadiri's acquaintances testified at trial as to their loans to him, they produced no evidence of any indebtedness. We found this testimony unpersuasive. We note, for example, that each acquaintance claimed to have canceled checks regarding the loan but failed to bring the checks to trial. Mr. Ghadiri testified that he made no interest payments on any of the alleged "loans". Mr. Ghadiri kept no record of any money that was lent to him. Moreover, Mr. Ghadiri testified that all payments that Maple Press and Acacia Press received were deposited in their respective bank accounts. Mr. GhadiriPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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