- 51 - Petitioners contend that Frank and Katherine did not have any likely source for the unreported income in the amounts determined by respondent. Petitioners assert that Frank was retired and seriously ill for all of the years in issue, and his only source of income was Social Security benefits. Petitioners further assert that Katherine’s palmistry business could not have generated the substantial receipts needed to produce the unreported income calculated by respondent for the years in issue. They maintain that she was seriously ill much of that period, and she was retired between January 1986 and August 1990 during which period her only income was Social Security benefits. They further maintain that Frank accurately reported his gambling winnings. As for the loan applications, petitioners argue that the applications were prepared by third parties, and that there is no documentary evidence to support the claim that Frank worked as a real estate broker for the years in issue. We believe that petitioners paint an overly dramatic picture of Frank’s and Katherine’s health conditions for the years in issue. In our opinion, the record does not show that Frank and Katherine were too ill to conduct the activities that would generate income from two of the likely sources identified by respondent (i.e., palmistry and gambling), and we have made findings that they did conduct those activities during the years in issue. The testimony of Dr. Kerry M. Schwartz, M.D. (Dr.Page: Previous 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 Next
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