-33-
We do not believe that the $90,000 was stolen from
petitioners. The record gives us several grounds on which to
doubt petitioner-wife's credibility. Petitioners concede that Il
Nam Lee never gave them any money. Petitioners contend that
petitioner-wife was referring to petitioner-husband's mother, not
her own mother. We find that to be an implausible attempt to
evade the effect of her prior reference to her mother.
Petitioner-wife admits to giving false information to U.S.
immigration officials to help Suil Peacock and K.C. Urbon
immigrate to the United States. She testified that she never saw
any of the financial records from the saunas, but she received
the sheets and the money when petitioner-husband was in jail in
1987. We are not convinced that $90,000 was stolen from
petitioners in January 1985.
5. Petitioners' 1985 Personal Expenditures
Respondent concedes that petitioners gave Suil Peacock
$48,940 in 1985, instead of $74,000 (a reduction of $25,060) as
respondent determined in the notice of deficiency.5 Petitioners
contend that respondent's $25,060 concession results in an
overpayment for 1985. We disagree. Respondent did not include
petitioners' living expenses in respondent's net worth
calculation and contends that this offsets respondent's
5 Petitioners' net worth is increased by the amount of the
funds they transferred to Suil Peacock.
Page: Previous 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 NextLast modified: May 25, 2011