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Petitioner testified that deposits to her general business
account consisted solely of money received as fees from her law
practice and money received from her mother. Petitioner also
testified that, when she deposited money that she received from
her mother, she recorded the source of funds as a “loan from me
or a loan from my mother.” On brief, petitioner explained that
she used the term “loan” in her deposit ledger to “describe money
that did not originate as earnings” but rather “belonged to her
mother”.
Petitioner provided copies of canceled checks for amounts
totaling $6,100. These checks show that petitioner deposited
into her general business account amounts totaling $6,100 drawn
from her mother’s account. Based on these canceled checks,
respondent conceded that an amount totaling $6,100 constituted
nontaxable transfers into petitioner’s account. Other than
canceled checks for the amount conceded by respondent, petitioner
offered no credible evidence of loans, transfers, or inheritance
from her mother. We do not accept petitioner's self-serving
testimony and handwritten ledger with respect to additional
loans, transfers, or inheritance without corroborative evidence.
Petitioner failed to overcome the presumption of correctness of
respondent's determination of unreported taxable income.
Allowing for concessions made by respondent, we uphold
respondent's determination of unreported taxable income.
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Last modified: May 25, 2011