- 12 - Washington, 459 F. Supp. 1020, 1095 (W.D. Wash. 1978). There is no evidence to support petitioner’s contention. Petitioner did not testify that the photo shop charged expenses on her credit cards, and her claim after trial that the photo shop charged its expenses on her credit cards is reason to disbelieve her trial testimony. Another reason for disbelieving petitioner’s trial testimony is the fact that she said in her answering brief that we should disregard her trial testimony relating to her photo store salary. It is not clear what parts of petitioner’s testimony we should believe under these circumstances. Petitioner contends that some of the money that she deposited was her own money that she had withdrawn for gambling and redeposited afterwards. Petitioner’s testimony in this regard was very general. She provided us no basis to decide which of the bank deposits were redeposits of money she had withdrawn. We conclude that, in addition to the $13,000 salary that petitioner earned each year from the photo store, petitioner had unreported income of $25,500 for 1993 and $5,486 for 1994. C. Whether Petitioner Is Liable for the Addition to Tax for Failure To File Her 1993 Income Tax Return Respondent determined that petitioner is liable for the addition to tax under section 6651(a) for failure to file aPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011