- 44 -
Q Okay. So this wouldn’t have been a buyout of
him, would it?
A Most likely it was a loan then.
Q Okay, but you paid it to him. Why didn’t the
company just pay it to him? Why was it done this way?
A I cannot recall what happened actually, but I
guess to get me an immediate credit. Back then, that’s
the only way it could be done, to give him his money
before he leaves.
Accordingly, we sustain respondent’s determination that the
Mansours received a $52,000 dividend distribution from Micca in
1996.
B. Petitioners’ “Other Income”
Petitioners have not challenged the computational accuracy
of respondent’s analysis of the deposits of unexplained amounts
of cash and checks from sources other than petitioners’ business
entities or those reported on petitioners’ income tax returns
into petitioners’ personal bank accounts. Petitioners have
presented neither evidence nor argument that these deposits are
not taxable or that these deposits do not represent income from
self-employment. Consequently, we hold that petitioners
understated the income that they received from self-employment in
the amounts set forth in the notices of deficiency.
C. Summary
An examination of the record indicates that respondent’s
determination of petitioners’ income for each of the years in
issue was not completely correct. The burden was on petitioners,
Page: Previous 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 NextLast modified: May 25, 2011