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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suggest that such funds were withdrawn from the account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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