- 11 -
from third-party loans. With one exception, petitioner did not
introduce into the record any evidence supporting his claim that
we found reliable and persuasive.8 For example, petitioner did
not proffer any notes or other evidence of indebtedness relating
to, any evidence of security for, or any books reflecting such
loans.9 We are, however, persuaded by the record before us that
petitioner's mother, Gloria M. Wynn, provided $23,800 of the
total amount that petitioner transferred to C & I during 1986 and
that, to that extent, the funds that petitioner spent during that
year were obtained from a nontaxable source.10
Based on our examination of the entire record before us, we
8 To support his position that he obtained the funds that he
transferred to C & I during 1986 as loans from third parties,
petitioner relies on certain alleged sales receipts from Linea
Pitti that purport to show that the store provided clothing at a
discount to certain customers who, he alleges, were the individu-
als who lent him the money that he invested in C & I. None of
the alleged purchasers of the clothing to which those purported
receipts pertain testified on petitioner's behalf, and we are
unwilling to accept petitioner's uncorroborated testimony about
them or those documents. In this regard, it appears to the Court
that the purported receipts in question are consistent with
petitioner's illegal money-laundering activities of which he was
convicted and that those activities, as well as the car wash
business that petitioner and his father owned, are the likely
sources of the funds that, during 1986, petitioner spent on
personal living expenses and transferred to C & I.
9 Indeed, C & I's financial workpapers belie petitioner's
contention that the funds in question were loans. These
workpapers indicate that the officers of C & I (viz., petitioner
and Ihsan Dura) were the individuals who, during 1986 (and the
first three months of 1987), transferred funds to C & I.
10 Respondent concedes as much on brief when she states: "Only
one of the documents * * * a check in the amount of $23,800 from
Gloria Wynn, petitioner's mother, appears to support the infer-
ence that petitioner received funds from a nontaxable source."
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