- 11 -
Petitioners contend that substantially all the funds
deposited into their Bank of Taiwan account in 1996 were
subsequently wire transferred to their Seafirst Bank account.
Petitioners bear the burden of proving such duplicate deposits.
See Estate of Mason v. Commissioner, supra at 657; Zarnow v.
Commissioner, 48 T.C. 213, 216 (1967).
Petitioners concede that there are no duplications for 1995.
Mr. Yang testified that 90 to 99 percent of the amounts withdrawn
from the Bank of Taiwan account in 1996 were transferred to the
Seafirst Bank account and specifically identified the
duplications. In 1996, the following transactions occurred on
the same days with respect to petitioners’ bank accounts:8
Date Withdrawal (Bank of Taiwan) Deposit (Seafirst Bank)
3/01/96 $7,306 $19,985
4/24/96 26,937 63,985
8/23/96 11,859 29,985
11/01/96 6,514 49,980
Mr. Yang testified that a family member would make the
withdrawal from the Bank of Taiwan account, add in more money,
and then wire this larger amount to the Seafirst Bank account.
Based on Mr. Yang’s explanation of the differences in amounts and
the corresponding nature of the withdrawals and deposits, we are
persuaded that respondent’s determination contained duplications.
We hold that the amounts withdrawn from the Bank of Taiwan
account on March 1, 1996, April 24, 1996, August 23, 1996, and
8Amounts are in U.S. dollars.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011