- 36 - 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'sPage: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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