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In the net worth computation, respondent characterized a
$6,200 payment made by petitioner in 1989 to Ms. Owca as a gift.
Petitioner disputes respondent’s characterization of his $6,200
payment to Ms. Owca and claims the expenditure was an investment.
Ms. Owca is petitioner’s former girlfriend. Petitioner also
disputes respondent’s characterization of a $10,000 payment made
in 1988 to Mr. C. Owca as a loan receivable. Petitioner claims
that he actually made the check out for $10, gave it to Ms. Owca,
and that Ms. Owca then altered it to $10,000. Petitioner’s
explanations in both instances are unbelievable. The $6,200
payment to Ms. Owca was made by a check containing the notation
that it was a gift. This was corroborated by Ms. Owca. The
$10,000 check was drawn on an account in the names of petitioner
and Helen Unger (petitioner’s mother). It bears a notation that
it was a loan, and the check does not appear to have been
altered.
On brief, petitioner disputes the accuracy of respondent’s
use of $5,000 cash on hand as of December 31, 1986. The amount
of opening cash on hand on December 31, 1986, was determined on
the basis of petitioner’s prior representations. Respondent’s
use of this amount of beginning cash on hand in the net worth
analysis does not render the analysis unreliable. See United
States v. Giacalone, 574 F.2d 328, 333 (6th Cir. 1978).
Petitioner also disputes the inclusion in the net worth
computation of bank accounts that were held jointly with his
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