Joyce E. Hastings - Page 19




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          respondent determined were sourced in receipts or income from her            
          law practice were from a nontaxable source.  Petitioner testified            
          that in 1977 she received $60,000 as proceeds of a life insurance            
          policy in connection with her husband’s October 1976 death.  She             
          further testified that she kept the $60,000 in a safe and used it            
          during 1986, 1990, and/or 1991 by making the deposits that                   
          respondent considers unexplained and determined to be sourced in             
          petitioner’s law practice.                                                   
               Respondent emphasizes that petitioner told respondent’s                 
          examiner that there was no cash on hand as of the beginning of               
          1986.  In the same vein, although petitioner contends that                   
          insurance proceeds represented a cash hoard that could explain a             
          nontaxable source for the deposits, she testified as follows:                
               Oh, yes.  I wanted to mention about my husband dying in                 
               <76.  I was flabbergasted when I discovered that,                       
               purportedly, there was income that I had not reported.                  
                    And the only thing I can say is that somehow I                     
               spent $60,000 between about 1977 and <87.                               
          In addition, petitioner, in showing that she was not offsetting              
          her losses from her horse activity against her legal income,                 
          explained that she had to borrow money to buy horses and pay                 
          expenses of her horse activity.  Petitioner’s borrowing at a time            
          when she purportedly possessed $60,000 in cash does not support              
          her claim that the alleged cash hoard existed 10 or more years               
          after she received it.                                                       






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