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the deposits made into their personal bank accounts are not
taxable. See Marcello v. Commissioner, 380 F.2d 509, 511 (5th
Cir. 1967), affg. T.C. Memo. 1964-303; Price v. United States,
supra at 678; DiLeo v. Commissioner, 96 T.C. at 871. The burden
of proof in these cases has not shifted to respondent under
section 7491 because petitioners failed to maintain adequate
books and records and to cooperate with reasonable requests for
information and documents. See sec. 7491(a)(2).
A. Distributions From Petitioners’ Business Entities
Respondent determined that the Mansours received and failed
to report dividend distributions from two C corporations: Micca
in 1996 and Ava Anthony in 1998. Respondent also determined that
the Mansours received and failed to report distributions from
three S corporations: Mina of Forest City in 1996, Mina of
Sanford in 1996, and Mansour Enterprises in 1998 and 1999. With
respect to the Gownis, respondent determined that they received
and failed to report dividend distributions from one
C corporation: Ava Anthony in 1998. Respondent also determined
that the Gownis received and failed to report distributions from
three S corporations: Tomson in 1998 and 1999, Mina of Forest
City in 1999, and Bishoy in 1999. In addition, respondent
determined that the Gownis received and failed to report
distributions from Pyramid in 1999. Respondent did not make a
determination as to Pyramid’s status in 1999, and there is no
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