Eddie Lee Williams - Page 8

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          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.  Petitioner               

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