- 3 -
not reflect income he received from sales of crops and livestock
as follows:
Source 1989 1990
Orangeburg Stockyard $14,237 $14,898
Weathers Farm Supply 2,146 -0-
Four Holes Farm -0- 6,800
Total 16,383 21,698
Petitioner’s tax returns for the years at issue were
assigned to C. Kevin Cox (Cox), a special agent in the Criminal
Investigation Division of the Internal Revenue Service (IRS).
Cox interviewed petitioner in October 1992.
In response to Cox’s questions about the source of funds for
specific expenditures, petitioner gave the following explanation:
He had borrowed what he needed from his father, Blease Judy
(Mr. Judy). Mr. Judy’s sister--petitioner’s aunt--Lillie Mae
Ellis, had died in 1985, leaving Mr. Judy $183,000. Mr. Judy had
withdrawn the entire inheritance from various bank accounts in
1985, and secreted the cash in an ammunition box that he kept
under his bed in the house he shared with petitioner’s family.
Mr. Judy had given petitioner permission to withdraw funds from
the ammunition box for expenses with the understanding that
petitioner would pay them back. On numerous occasions,
petitioner had helped himself from the contents of the ammunition
box, but was dilatory in repaying. At some point Mr. Judy had
discovered to his dismay how much of his inheritance had been
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