-13- affd. 519 F.2d 1121 (5th Cir. 1975). This intent may be inferred from circumstantial evidence, Powell v. Granquist, 252 F.2d at 61; Gajewski v. Commissioner, 67 T.C. 181, 200 (1976), affd. without published opinion 578 F.2d 1383 (8th Cir. 1978), including the implausibility of petitioner’s explanations, Bradford v. Commissioner, 796 F.2d 303, 307 (9th Cir. 1986) (and cases therein cited), affg. T.C. Memo. 1984-601; Boyett v. Commissioner, 204 F.2d 205, 208 (5th Cir. 1953), affg. a Memorandum Opinion of this Court dated Mar. 14, 1951. A. Tax Liability We have found that petitioner received wage income of $23,371.94 and pension distributions of $15,720 during 1993. Petitioner has not directed our attention to, and we have not found, anything in the record suggesting that any part of the pension distributions is excludable from gross income (as, for example, investment in the contract, within the meaning of sec. 72), except for petitioner’s arguments about the status of Federal Reserve Notes and the “Fair Market Value Exchange of his labor”. We conclude that respondent has shown by clear and convincing evidence that petitioner has more than $39,000 of 1993 adjusted gross income. In the notice of deficiency, respondent allowed deductions of $3,700 for the standard deduction and $2,350 for the personal exemption. Petitioner has not directed our attention to, and we have not found, anything in the record suggesting that he isPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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