Michael London - Page 57

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             computed by respondent for 1983 and 1985 are in any way                  
             linked to any of those assets.  For example, in the case                 
             of the bonds, the principal source of alleged gifts,                     
             petitioners ask the Court to find, based upon Agent                      
             Sullivan's testimony, that the bonds were cashed prior to                
             April 1980.  However, there is no testimony or other                     
             evidence concerning the manner in which this alleged sum                 
             was expended or indicating it has any relationship to the                
             net worth increases in 1983 and 1985.  See McGarry v.                    
             United States, 388 F.2d 862, 866-867 (1st Cir. 1967).  The               
             same is true of the proceeds from the sale of Mrs. Ida                   
             London's property at 400 and 402 Broadway for $27,000 in                 
             1980, and the proceeds from the sale of her home at                      
             Franklin Avenue in the amount of $28,000 in 1981.  In the                
             case of the funds that were invested in Treasury bills or                
             certificates of deposit through Mrs. Ida London's account                
             at Broadway National Bank, petitioners' proof suggests that              
             approximately $100,000 to $200,000 were invested through                 
             the account beginning in 1975, but there is no evidence to               
             suggest that such funds were withdrawn from the account                  
             prior to or during 1983 or 1985.  For the above reasons,                 
             we sustain respondent's determination of petitioners'                    
             taxable income for 1983 and 1985.                                        








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