- 3 - characterized by respondent as a “pyramid” wherein participants contributed money to petitioner that was deposited in petitioner’s bank account. As additional participants made contributions to the club, the previous contributors would go up one level and would move up again as further contributions were made. At some level, not indicated in the evidence, the participants at the top level received either all or part of the most recent contributions made at the lowest level. The record does not show how much or what percentage of these contributions went to petitioner for her services in conducting this activity. Respondent was unable to obtain any books and records from petitioner, as she denied that such activity even existed. Respondent determined, however, that petitioner realized income from this activity, and, since no income from such activity was reported on petitioners’ joint income tax return for 2000, through a bank deposits analysis, respondent concluded that petitioner realized net income of $72,434 from this gifting club during 2000. One of the witnesses at trial was a retired dentist who participated in the activity during the year at issue. He participated because he was having financial problems and believed he could realize money from this activity. According to his testimony, each entry in the club was $2,000, which could be made by one investor or split among several investors to make upPage: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011