Bruce David Cohen - Page 15




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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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