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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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