Peter and Mary Possas - Page 12




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          subtracted from this amount known deposits, including CDs that              
          petitioners had liquidated.                                                 
               Petitioners made an attempt to explain the source of funds             
          in their bank accounts.  Mr. Possas testified that they had                 
          purchased CDs at First Union Bank and cashed them in to use as a            
          downpayment on a house that they purchased in 1995.  Mr. Possas’s           
          testimony was vague.  The bank records that petitioners produced            
          to the Court, which purportedly show that the CDs they liquidated           
          were deposited into their bank accounts, do not clearly account             
          for the deposits.  We are not convinced that petitioners cashed             
          in CDs in excess of $7,064, which is the amount that respondent             
          identified and gave petitioners credit for in calculating                   
          unreported income.  See Clayton v. Commissioner, supra at 646.              
               Petitioners provided a copy of Mrs. Possas’s appointment               
          book that reflects the 347 hairdressing appointments in 1996 and            
          also indicates many of the services performed for her clients.              
          Mrs. Possas testified as to the prices of the various services              
          she performed.  Thus, there is a basis in petitioners’ records              
          for an estimate of their income, if not precise as to the total             
          amount of income, then at least accurate with respect to those              
          known appointments.  Petitioners made no effort, however, to                
          calculate their income from the hairdressing activity.                      










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