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some of the expenditures came from a painting company he owned,
but he could not remember the name of that company. Also,
petitioner’s testimony that he was involved in drug dealing only
to get drugs for his own use is made suspect by the testimony of
Detective Thomas M. Lau of the Baltimore County Police
Department. Detective Lau testified that he was introduced to
petitioner as an individual who could arrange drug purchases. He
also testified to petitioner’s participation in (1) an
approximately $20,000 drug transaction and (2) an aborted
$100,000 drug transaction. We found Detective Lau credible. We
do not think that petitioner’s participation, as described by
Detective Lau, is consistent with petitioner’s testimony that he
engaged in drug-related activities only to get drugs for personal
use; rather, we think that petitioner’s participation is
consistent with drug-related activities for pecuniary benefit.
In all substantial respects relating to the listed property, we
find petitioner’s testimony to be unbelievable, and we accord it
no weight.
Petitioner acknowledges his expenditures for the listed
property. Such expenditures are prima facie evidence of income
(see Tokarski v. Commissioner, supra at 77), and, except with
respect to one adjustment agreed to by the parties, petitioner
has failed to prove that the amounts shown as expenditures came
from nontaxable sources. Moreover, based on the plea agreement
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