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at least for some period of time, in a Washington, D.C., home
that was owned by petitioner and at least one of his brothers.
Petitioner's parents were in Florida on numerous occasions during
1991 and made several trips to other locations during the year.
In 1991, petitioner's father received all of his Social Security
checks at a Florida address where petitioner's grandmother
resided. During 1991, petitioner received gifts from his parents
totaling at least $20,000. Petitioner deposited into his
personal bank account checks made payable to his father totaling
$10,240.42. Petitioner's mother received an undetermined amount
of interest payments from investments during 1991.
OPINION
Unreported Income
Respondent determined that petitioner failed to report
$63,000 that was received from the sale of his medical/dental
equipment. This amount corresponds to the amounts received by
petitioner's mother from Dr. Kay. During 1991, petitioner
received payments of $33,000 and $25,000 and deposited into his
personal account checks payable to his father totaling
$10,240.72, in addition to his receipt of over $20,000 in gifts
from his parents.
Petitioner argues that the money that was received from
World Medical/Dental and from petitioner's father was in
repayment of loans.
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