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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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