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Michoff, Jr., did not file an income tax return for the 1986
or 1987 tax year.
In the 1988 tax year, Michoff, Jr., made payments of $6,000
toward the purchase of the Knight property.
Michoff, Jr., made deposits in the amount of $3,500 in his
World Savings Bank account in the 1988 tax year. These amounts
are not the total amount of deposits to this account in the 1988
tax year.
Michoff, Jr., reported total income for the 1988 tax year in
the amount of $10,135.
Michoff, Jr., and Kimberly Michoff expended the following
amounts in the 1989 tax year on the Green Ridge residence: $900
as a deposit; $29,500; and $8,797.6 The total amount of $39,1977
was spent by Michoff, Jr., and Kimberly Michoff on the Green
Ridge residence in the 1989 tax year.8
6 The $8,797 is the same amount that the Dickersons
expended on a cashier's check in the same year to purchase the
Green Ridge residence. Petitioners do not argue that this is a
duplication, and, without evidence to so indicate, we do not
assume that it is.
7 On brief, petitioner argues that “There was no proof
offered that Michael Michoff, Jr., had $39,197 in funds for the
Green Ridge property purchase.” We find the parties' stipulation
to this fact to be sufficient proof that this amount was expended
by Michoff, Jr., and Kimberly Michoff.
8 The stipulation reached by the parties states that the
funds were expended by Michoff, Jr., and Kimberly Michoff. The
deficiency for the 1989 tax year was asserted only against the
income tax of Michoff, Jr., however, because of the deemed
concession discussed below we do not inquire into what portion of
the funds were expended by Kimberly Michoff.
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