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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.
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