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that respondent determined petitioner’s opening net worth with
reasonable certainty.
In the stipulation relative to sentencing, petitioner
stipulated that with respect to taxable year 1989, he had income
from various taxable sources, including income from farm
property, sales of farming equipment, and payments for hunting
leases. Given that petitioner owned similar types of assets in
taxable year 1988, it is a fair inference that these assets
constituted a likely source of income for taxable year 1988 as
well.
At trial, petitioner sought to establish a nontaxable source
for the income reflected in respondent’s net worth analysis,
arguing generally that “I purchased the properties with other
people’s money. The majority of the money was somebody else’s”.
During the examination, respondent investigated these claims by
petitioner, interviewing persons from whom petitioner claimed to
have borrowed the money, and determined that petitioner’s claims
were not valid. Similarly, we do not find petitioner’s
uncorroborated testimony to be credible. The totality of the
evidence, including the stipulation relative to sentencing,
clearly establishes that petitioner made currency payments to
purchase ownership interests in the various properties in
question, often concealing his ownership interests in order to
avoid detection by tax and other law enforcement authorities.
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