- 14 - $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.Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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