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for this advance. Accordingly, check No. 1621 does not
constitute income to petitioners.
Petitioners argue that check No. 1655, dated
February 21, 1989, in the amount of $4,500, was issued to
repay Wholesale Fuels for cash advanced by Wholesale Fuels.
To support this claim, petitioners introduced a check
drawn on the Wholesale Fuels account for $4,500 dated
February 17, 1989. This check is payable to First
Interstate and was endorsed by H&B.
We have already found that Mr. Petty periodically used
money in the Wholesale Fuels account to pay expenses
incurred on behalf of H&B. We therefore find that check
No. 1655 represents a transfer of money between two
accounts used by H&B. Accordingly, we find that the
proceeds of check No. 1655 do not constitute income to
petitioners.
Also during 1989, petitioner signed two checks drawn
on H&B's First Interstate account and made payable to First
Interstate in the aggregate amount of $2,097. Neither
check bears any notation of its purpose, and the pegboard
ledger sheet on which these checks should appear was not
introduced into evidence. Petitioners have not provided
any explanation of these checks. There is therefore no
basis in the record on which to reject respondent's
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