- 8 - not belong to him exclusively. Petitioner insists that he and his partners, Mr. Ridge8 and Mr. Dill, shared the bank accounts and the funds deposited into them. We find no support in the record for this assertion. Petitioner has presented little evidence concerning the individual bank deposits at issue. Addressing the 1982 deficiency at trial, petitioner characterized the 1982 deposits as clients’ payments toward tax shelter investments. Petitioner did not produce any corroborating evidence, but rather asked “to be given the benefit of the doubt.” Petitioner did not specifically address the individual bank deposits for 1983 through 1987. Besides his testimony described above, the only evidence petitioner submitted was the testimony of his pro bono attorney, William Davidson (Mr. Davidson).9 Mr. Davidson testified that when he visited respondent’s office to examine petitioner’s bank records, he found the records in a state of “disarray”. After he examined the bank records, Mr. Davidson doubted whether respondent had properly considered “interbank transfers”, noting the large number of bank accounts petitioner used. However, Mr. Davidson did not allege any specific errors or otherwise 8The record does not contain Mr. Ridge’s full name. 9William Davidson assisted petitioner with his case pro bono during the time leading up to trial, but he did not enter an appearance before the Court on petitioner’s behalf.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011