Ali Motaghayer - Page 9




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          sources.  Specifically, we find that the source of the $8,700               
          deposit made on January 18 was a cash gift from petitioner’s                
          mother.  This is consistent with petitioner’s general claim and             
          apparently noted in Farsi in the check register.  Likewise,                 
          notations in the check register lead us to conclude that the                
          $1,000 deposit made on February 7, and deposits for $1,000 and              
          $400 made on March 7, were from nontaxable sources.  Finally,               
          given the amounts involved and the passage of time between the              
          deposits and respondent’s examination, we do not find it unusual            
          that petitioner could not satisfactorily explain the deposits               
          made on February 1, June 6, July 17, and December 13.  We accept            
          petitioner’s generalized testimony that these four cash deposits            
          were not from taxable sources.                                              
               Petitioner failed to satisfactorily explain the remaining              
          deposits, specifically:                                                     
               Date of Deposit               Amount                                   
               Jan.  6                       $3,635                                   
               Jan. 17                       5,340                                    
               Jan. 23                       4,000                                    
               May   5                       1,785                                    
               June 22                       800                                      
               Nov. 20                       1,700                                    
               Dec. 19                       3,500                                    










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