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which relates thereto is vague as to both timing and amount. Mr.
Cavender inquired during the examination of petitioner’s parents
regarding alleged loans and/or gifts, but petitioner’s parents
could not recall when or how much was remitted to petitioner.
Mr. Turley likewise admitted that he was unsure of the dates when
any particular loans were made. When questioned at trial
regarding a claimed 1987 inheritance from his grandmother,
petitioner indicated that the funds were used at least in part to
buy a condominium. Similarly, an alleged loan from petitioner’s
sisters was linked to the purchase of a home. Significantly,
petitioner never asserted that these nontaxable sums were
deposited in Bicycle Sport’s accounts.
We conclude that petitioner has not proven any of the
deposits into the Bicycle Sport accounts, other than the single
transfer identified by respondent, to be attributable to
nontaxable sources. (We also note, for the sake of completeness
and because the parties have made assertions with respect
thereto, that this record reveals no reasonably definitive leads
which respondent failed to check.) We hold that petitioner must
report business income from his sole proprietorship in the
amounts of $16,652.62, $51,065.04, and $47,119.74 for the years
1988, 1990, and 1992, respectively, in accordance with
respondent’s bank deposits analysis.
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