- 21 - B. Unidentified Deposits The question whether the unidentified deposits to the First Bank account are income to SCC merits further discussion. The record reflects deposits were made to account No. 893315300 in addition to the amounts traced to specific home sales. Respondent conceded that two of these deposits were loans from Mr. Strong’s parents but asserts that the rest of these deposits were income to SCC and Mr. Strong. Many of the deposits in dispute were of currency or were completely unidentified. Other deposits were by check purportedly from various individuals or entities. Respondent asserts that Mr. Strong used nominee names to hide his own identity on some of the deposited cashier’s checks, such as the three checks from Mr. Jeanotte in 1990 and two checks from his brother, Sean Strong, in 1994. Because of Mr. Strong’s inadequate records, respondent reasons under the bank deposits method of proof that these deposits are construction receipts absent evidence of any nontaxable source of the deposits. Respondent cites DiLeo v. Commissioner, 96 T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992); Clayton v. Commissioner, 102 T.C. 632 (1994); Tokarski v. Commissioner, 87 T.C. 74 (1986); and Nicholas v. Commissioner, 70 T.C. 1057 (1978). We agree with respondent that unless petitioners have shown that the funds came from nontaxablePage: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 Next
Last modified: May 25, 2011