- 31 - these expenditures.37 Additionally, some of the copies of checks that petitioner provided are made payable to “cash” for significant sums of money.38 Petitioner also alleges that he purchased vehicles for the benefit of Alviso and GMT with his personal funds for which he was not reimbursed. However, he fails to provide copies of the titles or any documentation which would demonstrate in whose names the alleged vehicles were purchased. Petitioner provides no evidence that he advanced/lent substantial amounts of money to Alviso or GMT except copies of canceled checks and his trial testimony.39 No payee testified as to these expenditures. There is no evidence of a repayment schedule, maturity date, special rights and duties of the parties, written memorialization of the debtor-creditor relationship, etc. On this record, we find that petitioner 37On brief, petitioner concedes that, to the extent he does not know the purpose for the expenditure, he is not now arguing that such expenditure is an adjustment to reconstructed income. 38For example, check No. 109 dated Mar. 20, 1990, for $9,645; check No. 112 dated Apr. 17, 1990, for $9,741.50; check No. 119 dated Apr. 30, 1990, for $9,847.00; check No. 118 dated Apr. 27, 1990, for $8,697.50; and check No. 117 dated Apr. 24, 1990, for $9,750.00. Despite providing the Court with copies of the aforesaid checks, petitioner is now not claiming these checks represent either advances or any other deductible business expense. 39The record indicates that petitioner did not make any such advances to Alviso or GMT. The balance sheets included with their 1990, 1991, and 1992 returns list “Loans from Stockholders” as $0.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
Last modified: May 25, 2011