Walter L. Medlin - Page 163

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          pieces of property--or a security interest in pieces of property            
          --not title--to the Cayman bank.  The Cayman bank would then                
          advance him funds using the property as a security.  Mr. Medlin             
          would then repay the loan in time.”                                         
               At best, John Kelly’s testimony provides a possible                    
          explanation for what the $70,000 check represented.  Petitioner             
          has offered no additional evidence or testimony to establish his            
          claim that the check was a loan.  Importantly, he does not argue,           
          nor has he shown, that title to, or a security interest in,                 
          property was ever transferred to Washington International for               
          what he purports to be $70,000 in loan proceeds.  Mr. Kelly’s               
          testimony that Washington International and Mr. Medlin were                 
          generally involved in loan transactions does not establish that             
          this amount was a loan.  Indeed, his testimony was inconsistent             
          with petitioner’s testimony at trial that he used the Washington            
          International trust account as a vehicle for deferring income               
          from real estate sales.  Petitioner has not established a link              
          between the unreported deposit and a nontaxable source of income.           
          We sustain respondent’s determination that the $59,000 deposit is           
          taxable as income to petitioner.                                            
               2.  Deposit on September 16, 1986, of $84,521.63                       
                                  FINDINGS OF FACT                                    
               On September 16, 1986, $84,521.63 was deposited into Mr.               
          Miles’s trust account.  Ledger card No. 70042 for that trust                






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