Bill McDonald - Page 24

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          Rule 142(a).  Petitioners have failed to carry their burden.  We            
          find petitioners’ explanation that the $6,024 in Gold checks was            
          written to McDonald and cashed by him for Maynard to be                     
          incredible.  The credibility of petitioners’ position is further            
          strained by the grossly disproportionate division of M&M’s income           
          to them.  Accordingly, respondent’s determination is sustained.             
               Miscellaneous Controverted Items Determined by Respondent To           
          Be Income--McDonald’s wife remitted three checks to Maynard                 
          during 1989 in the following amounts:  $995.90, $550, and                   
          $699.50.  McDonald’s daughter also remitted a $2,500 check to               
          Maynard during 1989.  Respondent determined that these payments             
          constitute income to Maynard.  In addition, Maynard purchased,              
          with cash, two $7,500 cashier’s checks from different banks                 
          during 1989, and respondent determined that the source of the               
          cash was untaxed income from clients that had not been deposited            
          into the bank or otherwise reported as income for financial or              
          tax purposes.                                                               
               McDonald purchased numerous cashier’s checks, mostly with              
          cash, during 1989.  The dates, amounts, and bank locations were             
          as follows:                                                                 

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