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1985, petitioner also disbursed a total of $29,465.80 from
Barnett money market to support the racing efforts. However,
petitioner never explained or established the source of these
funds. The $85,000 in Safra could not have been so used because
it was deposited in December 1985, and the Barnett expenditures
were made during February-December 1985. The record does not
show a transfer between the two accounts. Tables 1 through 3 in
the appendix detail these transactions. Table 4 reconstructs the
bank deposits and summarizes the various explanations; as set
forth therein, petitioner's net unexplained bank deposits amount
to $29,480.75 for 1985. Table 5 calculates petitioner's taxable
income for 1985 based upon the net unexplained bank deposits and
items of income and deductions that the parties stipulated to or
were included in respondent's notice of deficiency for that year.
The bulk of the unexplained bank deposits at issue were
deposited and disbursed in 1986, largely through Safra.
Virtually all the disbursed funds supported some aspect of the
powerboat racing entities. Petitioner disbursed funds for
freight delivery, insurance, advertising, work on the boats, and
rigger services. Petitioner also disbursed $100,000 to Len-Ed as
payment for services related to construction of the marina.
Dublin was a designated recipient for a portion of the $505,000
that LCP Associates, controlled by Lyon and others, deposited in
Safra during April as part of Ben's remittances from the card
club profits.
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