- 12 - were the source of petitioner's unexplained deposits for any of the years in question. Even accepting the alleged unusual business habits of both, we cannot accept that some $700,000 in loans exchanged hands. It is clear that funds did flow between Mr. Zurn and petitioner, but it is also clear that petitioner performed services for Mr. Zurn. We do not know the reasons for many of the transfers. At least in the case of the funds involved on the so-called Lot 2160 transaction, while we do not know details of the transaction, it certainly appears that from petitioner's position some type of taxable transaction took place and that transaction was not reported on petitioner's tax return. While it may be that Mr. Zurn did lend petitioner money, the paucity of records of both Mr. Zurn and petitioner makes it impossible to separate the possible wheat from the definite chaff in the transfers of funds between the two. Accordingly, we sustain respondent's determinations based on the bank deposit analyses for all the years at issue.10 The Accommodation Deposits During 1987 through 1989, Mr. Zurn and petitioner were engaged in some type of an alleged export activity under the name 10 There are other peculiarities. For example, the gross income on petitioner's 1986 Schedule C reflects $751,169 and a net profit of $7,713. In an income statement prepared by Mr. Moore for the first 9 months of 1986, petitioner's gross income was shown to be $853,122 with a net profit of $108,058. While Mr. Moore prepared the income statement, he did not prepare the 1986 tax return.Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
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