Monty Bisceglia and Patricia Bisceglia - Page 14




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          to show error in respondent’s determination that unexplained                
          increases in petitioners’ net worth are attributable to                     
          unreported taxable income.  That is to say, respondent’s net                
          worth analysis is wholly compatible with (and partly predicated             
          on) an assumption that petitioners might have realized more                 
          income than they consumed through “private expenditures.”                   
                         3.  The Cash Hoard “Lead”                                    
               Finally, petitioners contend that respondent failed to make            
          a reasonable investigation of the “lead” that their 1993                    
          beginning net worth, as reflected in respondent’s net worth                 
          analysis, incorrectly omitted $125,000 in cash, which petitioners           
          allege they had in Jack’s safe as of January 1, 1993.  There is             
          no evidence as to when petitioners may have provided respondent             
          this “lead”, which is predicated almost entirely on petitioner’s            
          and Jack’s testimony at trial.  Hence, there is no basis to                 
          conclude that respondent would have had reason to investigate               
          such a “lead” in the course of his examination.                             
               In any event, petitioners have failed to show that the cash            
          hoard existed after 1992, or that, if it did exist, it was a                
          source of nontaxable income during the years in issue.  On direct           
          examination, Jack testified that after petitioners obtained the             
          $135,000 Home Federal mortgage loan in June 1992, Monty signed              
          the check over to him, and that he (Jack) then cashed the check,            
          although he could not recall where he cashed it.  Inconsistently,           






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