- 49 -
property located at 79 Black Oak Road. Respondent then
computed petitioners' net worth for the years 1976 through
and including 1985. According to respondent's computation,
petitioners' net worth increased from $251,597 to
$1,908,738.01 during that time. The likely source of the
increases in petitioners' net worth is the profits from
Mr. London's unlawful activities. Respondent's net worth
statement is summarized in Appendix A hereto.
Petitioners attack the net worth statement on three
grounds. First, petitioners assert that respondent did not
take into account the balances in five bank accounts.
Second, petitioners contend that respondent used incorrect
balances with respect to three bank accounts. Finally,
petitioners argue that respondent failed to take into
account a cash hoard derived by petitioners as gifts given
from Mr. London's mother, Mrs. Ida London. We describe
each of petitioners' factual contentions in detail below.
Even if we assume that respondent's net worth
statement should be adjusted in order to take into account
all of petitioners' contentions, that would cause no change
in the taxable income determined by respondent for the year
1983 and 1985. This is shown in Appendix B hereto, in
which all of the changes suggested by petitioners have been
Page: Previous 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 NextLast modified: May 25, 2011