- 11 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011