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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.
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