- 13 - purchase the cashier's check, nor did they otherwise prove that the funds to purchase the check came from the El Dorado account. Petitioners have failed to establish that the cashier's check was purchased with funds from nontaxable sources. Dorothy Dickerson testified that some of the money that she deposited into her El Dorado savings account was from checks from Michoff, Jr., her grandson, and that the rest was from cash that she had gathered “here and there.” Petitioners further argue that the deposits came from gambling winnings that were offset by losses. For both the 1989 and 1990 tax years, the Dickersons reported substantial income from gambling as well as losses to offset that income. In performing the bank deposits analysis, respondent's agent backed out any gambling income that was reported on the Dickersons' income tax returns. The Dickersons have failed to prove any additional gambling losses beyond those already reported by them and allowed by respondent in the 1989 and 1990 tax years. Additionally, petitioners contend that the $9,200 which they paid toward their Primeline credit account came from their cash reserves as well as previous withdrawals from that account. Petitioners, however, offered no persuasive evidence to substantiate this claim. Petitioners have failed to meet their burden of proof regarding this amount. A $5,500 deposit made into the El Dorado account on March 20, 1989, came from a cashier's check purchased by Dan MaggardPage: 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