- 14 - Controls, Inc., in 1996 in time to include the amount on his return is implausible, given that the return was not filed until October 21, 1996, and Johnson Controls, Inc., had a statutory obligation to mail the form to him by the end of the preceding January.10 Petitioner’s attempts to identify nontaxable sources of income are similarly implausible. His claim that his mother gave him $10,000 was not substantiated. His claim that he deposited rent receipts belonging to his mother into his own checking account, and then paid over the receipts to his mother, was later qualified when the examining agent was unable to trace these amounts through his account. In the qualified version, petitioner claimed that the rent receipts were sometimes expended on repairs and sometimes kept by him for a period of time before being repaid to his mother. Even if the claims regarding the rent receipts were accepted, they would at most account for $11,700 of nontaxable source income annually, far less than the amounts petitioner failed to report in each year. In reaching our conclusion that petitioner’s various attempts to explain to the examining agent his failure to report income constitute evidence of fraud, we also take note of the 10 Information returns must be delivered to the person with respect to whom the information is required by Jan. 31 of the year following the calendar year in which payment of the reported income is made. See sec. 6041(d).Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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