- 57 - 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$200,000 were invested through the account beginning in 1975, but there is no evidence to suggest that such funds were withdrawn from the account prior to or during 1983 or 1985.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.Page: Previous 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 65 66 Next
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