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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. Ghadiri
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