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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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