Salaheddin Ahmad Ahmad - Page 18

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          tax.  The parties stipulated that the deposit of $40,544 into               
          petitioner's checking account was a transfer of the balance of              
          savings account #1.  This amount is a redeposit; therefore, it is           
          not gross income.  Based on the entire record, we find petitioner           
          has met his burden of proving the check for $1,988 payable to               
          Gibson, which petitioner cashed for her by depositing in his                
          account, is not taxable income to him.                                      
               Our finding that petitioner has met the burden of proof as             
          to the source of these deposits is not a grant of credence to               
          petitioner's claims regarding the source of his other deposits.             
          Nor does the evidence presented by petitioner, which showed that            
          some of the deposits were not income, establish that the use of             
          the bank deposits method was invalid or arbitrary.  Estate of               
          Mason v. Commissioner, 64 T.C. at 656.  Having reached that                 
          conclusion, we will comment in more detail on petitioner's                  
          evidence.                                                                   
               Petitioner testified that the sources of his other deposits            
          were family transfers, repayments of loans he earlier made to               
          friends and associates, and cash reimbursements for checks he               
          wrote to pay the bills of others.  Petitioner provided scant                
          evidence to corroborate his claims.  For example, to substantiate           
          his claim that family members transferred money to him,                     
          petitioner submitted a copy of a wire transfer that originated in           
          Jordan and was sent to Saleh in Calhoun.  The wire transfer is              
          for $15,000 and is dated April 12, 1990.  We find, however, that            




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