Celeste Bonner and Louis Bonner, Jr. - Page 4




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                    Mrs. Brown testified that petitioner was paid by cash and by                                                                                           
                    check.  Mrs. Brown kept a payment ledger that indicates that the                                                                                       
                    Browns paid petitioner routinely during 1998 for his work.  The                                                                                        
                    record contains seven checks that are appropriately shown on the                                                                                       
                    ledger and were endorsed by petitioner.  The ledger also contains                                                                                      
                    the initials “LB” by most of the entries made.  Mrs. Brown                                                                                             
                    testified that they were petitioner’s initials.  The formation of                                                                                      
                    the letters “LB” on the ledger strongly resembles the formation                                                                                        
                    of those letters on the canceled checks that were endorsed by                                                                                          
                    petitioner.  In addition, a written agreement for independent                                                                                          
                    contracting services, dated January 2, 1998, was executed by                                                                                           
                    petitioner.                                                                                                                                            
                              Petitioner initially denied receiving any money from the                                                                                     
                    Browns.  When confronted with the canceled checks, he reluctantly                                                                                      
                    conceded that he had received those checks.  Furthermore, when                                                                                         
                    petitioner was asked what he lived on during 1998, he was totally                                                                                      
                    evasive stating that “I’m not just helpless.  I do little                                                                                              
                    ordinary things.  I’ve made a dollar bill [sic?].”  Those dollars                                                                                      
                    “here and there” were not reported on petitioners’ tax return.                                                                                         
                    In short, we accept the Browns’ (and respondent’s) version of the                                                                                      
                    transactions between petitioner and the Browns.                                                                                                        
                              Next, we turn to the question of the penalty.  Section                                                                                       
                    6662(a) provides that, if the section applies, there is imposed a                                                                                      
                    penalty in an amount equal to 20 percent of the portion of the                                                                                         






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