- 34 - We simply do not believe petitioners' paper trail of promissory notes, deeds of trust, assignment agreements, and assumption of liabilities agreements tells the whole story because the funds that were loaned to Chestnut Grove and Group M in 1987 and 1988 previously traveled a circuitous route, which begins and ends with petitioner, in direct contradiction to petitioners' assertion that Mr. Bell was the ultimate source of those funds. In sum, we have considered all of the evidence presented by petitioners, but, because the Yakima interest payments were credited to the Aldergrove account on December 26, 1991, and, on that date, petitioner controlled Aldergrove partnership matters and benefited from and controlled the funds in the Aldergrove account, we are not persuaded that the Yakima interest payments represent anything other than interest paid to petitioner on account of loans made by petitioner. D. Conclusion We hold that the 1991 interest payments are taxable to petitioners. III. $25,000 Deposit A. Introduction In the notice of deficiency, respondent determined that $317,160 was deposited in bank accounts held in the name of petitioners during 1991 and that those deposits were unexplained.Page: Previous 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 Next
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