Charles Y. and Jin Y. Choi - Page 14




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         $100 bills from unknown individuals who had traveled to the                  
         United States from Korea.                                                    
              We note at the outset that intrafamily transactions are                 
         subjected to closer scrutiny.  Caligiuri v. Commissioner, 549                
         F.2d 1155, 1157 (8th Cir. 1977), affg. T.C. Memo. 1975-319; Perry            
         v. Commissioner, 92 T.C. 470, 481 (1989), affd. 912 F.2d 1466                
         (5th Cir. 1990).  The witnesses’ stories were strikingly similar,            
         and, curiously, none of the witnesses knew the person who gave               
         them the alleged currency.  We also find it curious that the                 
         alleged deliveries of relatively large amounts of currency were              
         given to different family intermediaries of petitioner’s parents             
         and that no deliveries were made directly to petitioner’s                    
         parents.  Finally, there is no documentary evidence of the                   
         existence of the alleged cash that petitioners argue was infused             
         into the operation of Gene’s.  In particular, the three bank                 
         accounts in this record do not reflect the deposit of any cash.6             
              With respect to petitioners’ cash gift argument, respondent             
         notes that the alleged cash was not available from the Choi                  
         families’ Korean lawsuit, at very least, until 1993, whereas all             
         of the witnesses testified to receiving the money during 1991 and            
         1992.  Because this case involves a reconstruction for 1991 and              
         1992, it is imperative that petitioners show the infusion of cash            

              6 The deposit account received check deposits from Gene’s,              
         and the operating account received transfers from the deposit                
         account.                                                                     





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