Oliver E. Stubblefield - Page 19

                                   - NEXTRECORD  -                                    
          creditworthy as he claims to be, petitioner would have made some            
          14 payments before 1991 even began, and the outstanding balance             
          would have been no more than $235.                                          
               Also noteworthy is the fact that on the credit application             
          for the September 1989 purchase, petitioner represented that he             
          had been working as a barber/stylist for at least 1 year and 9              
          months.  However, petitioner reported no barber income on his               
          1988 income tax return.                                                     
               Moreover, on the credit application for not only the                   
          September 1989 purchase but also for the January 1991 purchase,             
          petitioner represented that his weekly "take-home" pay for                  
          working as a barber/stylist was $350.  "Take-home" pay of $350              
          per week for 50 weeks amounts to $17,500 for the year.  Here it             
          should be recalled that respondent's determination of                       
          petitioner's barber income was $17,170.  It should also be                  
          recalled that respondent's determination was based strictly on an           
          analysis of petitioner's bank accounts and therefore did not take           
          into account the cash that petitioner pocketed and did not                  
          deposit.12                                                                  



          12 Although we accept the possibility that petitioner's                     
          sister and cousin may have, on occasion, reimbursed petitioner              
          for some purchase, see supra note 3, we do not think, and it has            
          not been shown, that the aggregate amount of any such                       
          reimbursements exceeded the amount of petitioner's barber income            
          that was pocketed and not deposited and, therefore, not included            
          in respondent's bank deposits analysis.                                     




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