- 6 - on the bill of lading because the Jeep Cherokee was received by a shipping agent. Petitioner did not produce receipts or shipping documents for other items that he purchased for, and shipped to, Mr. Emmanuel. Petitioner did not produce other records from the currency exchange transactions, such as the letters faxed to Mr. Emmanuel or the designated recipient, because “there was no need to keep it” once the transaction was over. Petitioner explained that he accounted for the U.S. dollars that he held on behalf of Mr. Emmanuel by using his bank account statements. The record contains account statements from a Citibank account that petitioner co-owned with two other individuals, Ebenezer Soh Kengne and Daniel P. Fleret. Petitioner did not explain, and it is not clear from the record, who owned the funds in the Citibank account. Respondent, utilizing a bank deposits methodology, determined that petitioner underreported $39,444 of income.4 Respondent’s agent explained at trial that respondent first examined petitioner’s income tax return for the 1996 tax year in connection with a tax return preparer penalty. Respondent determined that petitioner had unexplained bank deposits of 4 Petitioner testified at trial that he received income from his family in Cameroon and rental income from two houses that he owns in Cameroon. Respondent did not make a determination or a claim with respect to these two sources of income. Therefore, such matter is not at issue.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011