William Kale - Page 14

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          concerning a certain credit, which was passed through to the                
          trusts from a partnership called Traylor Syndicate (Traylor).  It           
          was this credit, according to petitioner, which paved the trail             
          to the Cynwyd Group.  We do not see how.  Logically, the next tax           
          returns that petitioner should have examined were those of                  
          Traylor, through which the credits passed to the trusts.                    
          However, the next returns which petitioner did, in fact, examine            
          were those of Cynwyd Investments and Saligman Capital.  Yet, the            
          trusts were not partners in either of those partnerships.  We               
          find no basis for petitioner’s extension of his investigation to            
          include the Cynwyd Group, other than that he was paid by Toll to            
          do so.  Accordingly, we disregard petitioner’s testimony.                   
          Petitioner offers little other evidence to aid him in meeting his           
          burden of proof.                                                            
               We find, therefore, that petitioner has failed to carry his            
          burden of proving that he did not receive unreported bribe income           
          of $105,000 in 1980 and $7,500 during 1982 and 1983.                        
          Additionally, petitioner has not shown that respondent’s method             
          of allocating the $7,500 equally between 1982 and 1983 is                   
          unreasonable.  Harbin v. Commissioner, 40 T.C. at 377.                      
          Accordingly, we sustain respondent’s deficiency determinations.             
          II. Additions to Tax for Fraud                                              
               Respondent determined that petitioner is liable for                    
          additions to tax for fraud under section 6653(b) for 1980, and              
          section 6653(b)(1) and (2) for 1982 and 1983.                               




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