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by petitioner personally or by petitioner with the alias Daniel
Dunn. Some of the disbursements from the account were channeled
to a New Jersey bank account in the name of Hill Winery
Associates which had no business purpose other than to pay major
personal expenditures of petitioner and for which petitioner's
father picked up all the bank statements. During 1981, the sole
check disbursed from this account was for $45,000 and was signed
by petitioner, was made payable to petitioner, and was ultimately
deposited by petitioner in his New York City checking account.
Accordingly, we hold that petitioner must include $50,000 and
$150,000 in his 1981 and 1982 income, respectively.
Petitioner similarly has failed to prove that he did not
exercise dominion and control over the Pares Y Nones, S.A.
account. The evidence has shown that petitioner was involved in
opening and operating the account. Petitioner had obtained a
survey on a ketch; then approximately 1 month later, he directed
a Panamanian attorney to wire $42,500 from the account.
Petitioner was signatory on behalf of the seller of the Bermuda
ketch. Accordingly, we find that petitioner must include the
$50,000 deposited by Landing into the Pares Y Nones, S.A. account
in his 1982 income.
Additionally, respondent contended that petitioner should
include in income the amount of renovations on his home paid for
by Landing. The renovations were first discussed by Finley,
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