Eva J. Madigan - Page 7

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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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