- 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 Yang testified that 90 to 99 percent of the amounts withdrawn from the Bank of Taiwan account in 1996 were transferred to the Seafirst Bank account and specifically identified the duplications.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 We hold that the amounts withdrawn from the Bank of Taiwan account on March 1, 1996, April 24, 1996, August 23, 1996, and 8Amounts are in U.S. dollars.Page: Previous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
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