- 34 -
Petitioners argue that many of these deposits came from
their wages, which were reported on their individual income tax
return. However, they have offered no proof of this beyond
vague, unsubstantiated testimony. Additionally, respondent's
revenue agent backed out net income that was reported on
petitioners' return when she performed her bank deposits
analysis.
Michoff, Jr., contends that a $3,000 deposit which is in
issue came from the sale of a Porsche to Bill McKay. Michoff,
Jr., contends that he purchased the Porsche for $2,000 and put
$1,000 worth of repairs into the car. Other than his own
testimony, which we find lacking in credibility, Michoff, Jr.,
presented three exhibits as proof of his purchase price and cost
of repairs; these exhibits lack any probative value as well as
any indicia of trustworthiness.10
10 As proof of his purchase price Michoff, Jr., submitted
two exhibits to the Court. First, Michoff, Jr., submitted a
document from the State Board of Equalization Occasional Sales
Use Tax Unit. This document is a letter which states that
Michoff, Jr.'s, Certificate of Purchase Price, indicating his
purchase price of the car, was selected for routine verification
and that he would need to submit other evidence providing
verification of value. This document proves nothing as it is
merely a request for information. Second, Michoff, Jr.,
submitted a bill of sale purportedly showing that he purchased a
Porsche for $2,000. However, this bill of sale lacks a Vehicle
Identification Number, a transfer date, and the address of the
seller. There is no indication that this is an actual bill of
sale.
As proof of the cost of repairs, Michoff, Jr., submitted a
pile of receipts. These receipts do not show for what car the
parts were ordered or the work done. Additionally, Michoff, Jr.,
included receipts dated as late as May 28, 1991, for a car which
(continued...)
Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 NextLast modified: May 25, 2011