- 7 -
Petitioner further claims that with four exceptions
(discussed below), the source of the cash deposits was a gift
from his mother. According to petitioner, his mother gave him
$35,000 in November of 1994. Assuming, without finding, that
this event occurred, we find it unlikely that a single cash gift
made to petitioner in 1994 would result in the pattern of the
cash deposits here under consideration.
Petitioner testified that one of the deposits made in
January consisted of the proceeds of the sale of an automobile
and that three deposits were made from the proceeds of checks
payable to him from his brokerage account. Petitioner testified
that he gave the brokerage account checks to his brother, who
gave petitioner cash in return, which was then deposited into
petitioner’s checking account. According to petitioner, it was
easier to have his brother cash the brokerage account checks
because brokerage account checks deposited into petitioner’s
checking account took 2 weeks to clear. Petitioner could not
identify the specific deposits to which the foregoing
explanations related. We, like respondent, are not convinced
that any of the cash deposits were from the sale of an automobile
or the proceeds of brokerage checks cashed by petitioner’s
brother.
After careful consideration of the record, however, we are
satisfied that some of the cash deposits were from nontaxable
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011