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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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