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unreported income. Holland v. United States, 348 U.S. 121
(1954); Parks v. Commissioner, 94 T.C. 654, 661 (1990).
Alternatively, where the taxpayer alleges a nontaxable source,
the Commissioner may satisfy her burden by disproving the
nontaxable source so alleged. United States v. Massei, 355 U.S.
595 (1958); Parks v. Commissioner, supra.
We find that respondent has proven by clear and convincing
evidence a likely source of the underreported deposits; i.e.,
that they are income from the Yogurt Station's business.
We also find that respondent has disproved, by clear and
convincing evidence, the nontaxable source alleged by
petitioners. Mr. McGirl's explanation of loans from Mr.
McAllister is implausible and incredible. The McAllister loans
were supposedly included in the Yogurt Station's deposits. In
1991, the alleged loans were only $7,000, yet the Yogurt
Station's deposits substantially increased from the previous year
when the alleged loans were $30,500. This inconsistency was not
explained by petitioners. Mr. McAllister's testimony was vague
and incredible. Further, we find it implausible that Mr.
McAllister would have a $25,000 cash hoard given his financial
situation during the years in question. Thus, respondent has
proven, by clear and convincing evidence, that an underpayment of
tax existed with respect to each of the years under
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