Miriam Lawrence - Page 23

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            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 this                              









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