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W.G. Boyd from the Medlin/Partin ledger card. However, this has
little relevance in determining whether the $140,000 Dean Witter
check was a nontaxable source of income; i.e., a loan. Moreover,
the considerable difference between the amount of the Dean Witter
check, $140,000, and the total amount of the disbursements,
$97,893.78, contradicts petitioner’s testimony that the purpose
of the loan was to make a mortgage payment.64
Also, we are not inclined to accept petitioner’s testimony
that the entries on the Medlin/Prather Ranch Property ledger card
were mistaken entries by Ms. Goodman that were subsequently
corrected. Unlike the deposit in 1986, which we held was
attributable to a mistaken entry, the entry on the ledger card at
issue here was not simply corrected with a transfer in an
equivalent amount to another card. Instead, there were three
offsetting entries: (1) A transfer to the Medlin/Partin ledger
card on July 12, 1988, of $97,893.78; (2) a transfer to the
Medlin/Malfa card on July 13, 1988, of $24,871.72; and (3) a
transfer to the Medlin/general ledger card on July 13, 1988, of
$17,234.50. We cannot conclude that the deposit entry on the
Medlin/Prather Ranch Property was necessarily a mistake and that
the $140,000 should have been transferred to the Medlin/Partin
64And, indeed, it could indicate that the transaction was in
fact a sale of the property. Proceeds from a sale of property
would not be a nontaxable source of income.
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