- 23 -23 the statements made by Lawrence and Abraham at the summons conferences, to constitute reasonable explanations, particularly in view of the extent and magnitude of the transactions, the inconsistent statements made concerning interest, and the complete lack of any corroborating documentation on the point. After listening to 2 days of testimony and reviewing literally thousands of pages of exhibits, the Court still has not heard a reasonable explanation for the transactions occurring between Abraham and Lawrence. If the transactions represented loans between the two, the loans were not reflected as such on any documents. The fact that Appeals Officer Hill accepted Haddad's transfer report as support that neither Abraham nor Lawrence realized taxable income from the various bank transactions occurring between the two is certainly not conclusive that Agent Red's adjustments and the position of respondent that resulted therefrom were unreasonable. We have many times stated that the Commissioner's concession of an issue does not necessarily lead to a finding that her position was not substantially justified. See, e.g., Wilfong v. United States, 991 F.2d 359, 364 (7th Cir. 1993); Sokol v. Commissioner, 92 T.C. 760, 765 (1989); Wasie v. Commissioner, 86 T.C. 962, 968-969 (1986). Furthermore, in thisPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
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