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receipts into the AT #3 account, the Society National Bank
account, the Huntington Bank account, and the Independent Savings
Bank account. These deposits totaled $112,531.56. We conclude
that deposits into these accounts constitute income to petitioner
in 1988. After reducing the deposits by the $50,000 petitioner
reported on his tax return, petitioner had $62,531.56 in
unreported income from medical services in 1988.
B. Rental Income
Respondent contends that petitioner received rental income
in the amounts of $1,763, $4,195, $3,960, and $3,125 in 1985,
1986, 1987, and 1988, respectively. Petitioner contends that he
received rental payments as an agent.
Section 61(a)(5) includes in gross income all income from
the rental of property. Ms. Alshabani testified that she rented
property from petitioner and made rental payments to him. Other
renters made their checks payable to petitioner. Petitioner
endorsed these checks.
Petitioner presented no evidence that he paid over any of
the money he received as rent to the "principals" for whom he was
supposedly acting as an agent. Furthermore, it was not until May
of 1989, well after the IRS began investigating petitioner and
petitioner's father had died, that tax returns were filed
reporting that the rental income belonged to petitioner's father.
Although Ms. Alshabani testified that she rented property
from petitioner and paid him rent, there is no evidence of the
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