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inheritance in the amount of $9,500 and gifts in the amount of
$8,000.
Revenue Agent Bacino requested petitioners to provide
substantiation, including written documentation, for their claim
regarding the receipt of loans, inheritance, and gifts. In this
regard, petitioners provided Revenue Agent Bacino with the names
of certain individual lenders. Revenue Agent Bacino was able to
confirm the existence of one such loan in the amount of $50,000
and adjusted his bank deposits determination by that figure.
Revenue Agent Bacino determined that there was no
documentary evidence to establish the existence of any additional
alleged loans. There were no written agreements or terms or any
principal or interest payments made towards these loans. He
therefore attempted to verify the existence of the alleged loans
from the listed individuals through telephone conversations,
meetings, and correspondence.
A number of these individuals provided written or oral
statements attesting to loans to petitioners. However, Revenue
Agent Bacino determined that he could not rely on the statements
made by these individuals without further substantiation. He
found that for the most part the individuals that petitioners
listed as lenders were relatives or long-time friends of
petitioners who only provided vague and general statements
regarding the loans.
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Last modified: May 25, 2011