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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.
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