Luis Acle, Jr. - Page 15

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          Bank; these checks represent mortgage payments by petitioner.               
          Most of the remaining checks were written to petitioner himself or          
          to Wells Fargo, presumably indicating that on some occasions                
          petitioner was withdrawing cash from his account.  There is no              
          evidence that any such withdrawal was redeposited into                      
          petitioner’s account.  To the contrary, there is evidence that at           
          least a portion of such funds was used to make payments on a line           
          of credit or another loan.  In summary, we find that the Wells              
          Fargo checks do not refute any aspect of respondent’s calculation           
          of petitioner’s unreported income.                                          
               Other than the two general arguments discussed above,                  
          petitioner has not presented any specific objections to                     
          respondent’s reconstruction of petitioner’s income.  For example,           
          petitioner has not argued that any individual deposit is from a             
          nontaxable source, nor has petitioner asserted, or provided                 
          evidence tending to show, that any deposit was from an alternative          
          source, such as a savings account.                                          
               Finally, petitioner summarizes his argument that respondent’s          
          determinations are in error by stating:                                     
               I think that there is clear evidence of the fact that there            
               is a certain amount of necessary recycling of this money for           
               the reasons that I have explained to the points that there’s           
               no way that anybody could say that this clearly reflects               
               income.                                                                
          We disagree with petitioner.  While respondent’s reconstruction of          
          petitioner’s records certainly is not exact, we find the                    






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