Thomas Rice - Page 8

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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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