- 18 - testified that petitioner obtained the UCC financing statement to protect his personal items from levy for unpaid taxes. Her testimony is consistent with the sequence of events established by the evidence. The ledger sheet and promissory notes that were given to respondent in 1994 are unreliable. G. Rodriguez and the revenue agent both testified that they had been informed that there were no loans from petitioner's family. The documents were not provided to the IRS until 1994, 2 years after the agent requested the information. Additionally, the address on the December 1990 invoice was listed as Ave. Hidalgo, #407 in Toluca, Mexico. Petitioner was residing in San Antonio at the Dominion in 1990. The address on the invoice was the address that petitioner used after returning to Mexico in 1991. Petitioner also argues that the 200,000,000 pesos deposited in his account at Banca Cremi was a loan and that petitioner planned to use the proceeds of that loan to pay back the family loans. The only document in evidence on this point is a deposit slip in Spanish for 200,000,000 pesos deposited into a bank account. There are no loan documents or any indication that the deposit was a loan or that the proceeds were going to be used in any particular manner. Further, using petitioner's exchange rate of 2,889 pesos per dollar, the 200,000,000 pesos would convert to approximately $69,228, an amount insignificant in comparison to the total amount that petitioner claims to owe his family.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011