- 7 - for services rendered. When we consider these three additional facts in conjunction with the fact that petitioner deposited the checks drawn by Ms. Burley into the above-mentioned business account, we have little trouble concluding that respondent has connected these checks to a likely source of taxable income. Petitioner failed to offer any evidence to the contrary. We reach the same conclusion with respect to the two checks drawn by Ms. White. Although the evidence in the record regarding the checks drawn by Ms. Burley is more convincing than the evidence in the record regarding the checks drawn by Ms. White, the latter evidence is sufficiently persuasive, and we conclude that respondent has adequately linked the checks drawn by Ms. White to a likely source of taxable income. Petitioner failed to offer any evidence to the contrary. We reach a different conclusion, however, with respect to the checks that petitioner received from Vickie Conant (Ms. Conant), Ted Elcross (Mr. Elcross), and Prudential-Bache. Each of these checks was made payable to petitioner personally and none contains markings that suggest that it was received in exchange for services rendered. All that is certain is that petitioner deposited these checks into her business bank account. As we noted above, however, this alone is not sufficient to persuade us that these deposits stem from a likely source of taxable income. The connection proffered by respondent is too tenuous.Page: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011