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determinations (i.e., using unreliable records and testimony), or
reject respondent’s determinations. We shall do the latter.
We also note that respondent did not utilize the net worth
method for purposes of determining petitioners’ unreported income
but asserted that petitioners used the proceeds from the bingo
games to support numerous gambling excursions. The evidence,
however, does not so establish. Petitioners had sufficient funds
from other sources (e.g., income from Salvage Brokers and
substantial rental income received from the charities).
Petitioners have established, by a preponderance of the
evidence, that respondent’s determinations are incorrect. Thus,
we are compelled to reject the determinations. Contentions we
have not addressed are irrelevant, moot, or meritless.
To reflect the foregoing,
Decision will be entered
for petitioners.
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Last modified: May 25, 2011