- 8 - not all of the supporting documents are in the record, nothing in the record calls into question the accuracy of these summaries. Petitioner himself does not dispute their accuracy. In petitioner’s Objections to Respondent’s Stipulations, he summarizes his position in this case, stating that he does not contest that he received the amount of * * * money of $111,991.00 and $11,747.00 for the years of 1989 and 1990. Petitioner does object to these amounts being described as taxable income and subject to tax penalties under IRC 6651(a)(1) and 6654 * * * . Also Petitioner * * * from 1980 to 1986 * * * took out large cash advancements from numerous credit card accounts, which totaled in excess of $250,000 * * * . Additionally, Petitioner will show this Court and the Respondent that he can produce documentation (Credit Card Information), that will make up the difference of $76,769.24, to balance out the total amount of $123,738, that the Respondent claims is earned and or gross income that is subject to taxation, but that the Petitioner rebutts [sic] as being income at all and not subject to taxation by the Internal Revenue. That said claim by the respondent is arbitrary and exaggerated in that said monies were not derived from any type of income that could be subject to any tax by the federal government. Petitioner’s testimony at trial in support of this argument can be summarized as follows: The cash petitioner used for the majority of the various deposits and expenditures during the years in issue was obtained through credit card cash advances. Petitioner obtained these advances in or before 1986; he then gave the cash to his father, who kept it in a suitcase in the trunk of a car in his backyard. Petitioner retrieved the cash from his father in 1987, but held onto it until the years in issue when he began making periodic cash deposits of varying amounts into several different checking accounts. PetitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011