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Moreover, we are skeptical of petitioners' argument
that Mrs. Ida London was able to accumulate such large sums
of cash by her frugal lifestyle. First, the only source of
Mrs. Ida London's income was London's Cafe, Inc., which did
not report any taxable income in the 10 years from 1976
through 1985. Furthermore, the tax paid by petitioner's
parents during the last 15 years of Mr. Isadore London's
life shows that the couple earned very little income and
Mrs. Ida London filed no tax return during the last 7 years
of her life. Petitioner's parents did not file gift
or estate tax returns during 1966 through 1994, and they
left no probate estate. Furthermore, on February 11, 1981,
when Mrs. Ida London sold her home on Franklin Avenue, she
rented an apartment located in a subsidized housing
project.
It is unnecessary to resolve the factual and
evidentiary issues presented by petitioners' cash hoard
defense because even accepting petitioners' assertion that
Mrs. Ida London transferred her property to them, we would
still hold for respondent. This is true because even if we
were to accept petitioners' position that Mrs. Ida London
transferred the subject assets to them, there is nothing in
the record to establish that the net worth increases
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