- 25 - 1989 Date Amount Location Purchased Apr. 20 $3,000 Commerce Savings June 8 9,000 Commerce Savings June 8 10,000 Bank of Alex Brown1 June 12 9,000 Wells Fargo June 14 1,432 Wells Fargo June 14 2,594 Wells Fargo 1 Respondent conceded that the $10,000 cashier’s check was from a source that was not taxable to McDonald. Respondent determined that these amounts, along with $1,000 cash deposited by McDonald in the M&M trust account, constitute income to McDonald because 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. With respect to the $2,500 item from McDonald’s daughter to Maynard, petitioners argue that Maynard first gave the $2,500 to McDonald’s daughter, who, in turn, gave it to McDonald to purchase the $2,594 cashier’s check that went to purchase the home placed in McDonald’s wife’s name. Ultimately, petitioners would have us believe that this circuitous route for the $2,500 was concluded when McDonald’s daughter repaid Maynard. Other than the $2,500 item, petitioners make no particular argument with respect to the cash items that respondent determined were income to Maynard. With respect to McDonald, it is contended that he had available to him from both taxable and nontaxable sources almost $21,000 with which to purchase the cashier’s checks remaining in controversy. Ostensibly, the $21,000 represents all of McDonald’s sources from which he was able to make applications, which would include, in addition to purchasingPage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011