Khosrow Ghadiri and Turan Mirhady Ghadiri - Page 11

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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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