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(1994) (citing DiLeo v. Commissioner, 96 T.C. 858, 868 (1991)),
affd. 959 F.2d 16 (2d Cir. 1992).
Respondent produced bank deposit records, as well as copies
of petitioners’ checks, showing that petitioners deposited
$54,000 into their Leadenhall bank account. Mr. Wright had
initially told the IRS agents assigned to his case that the
$54,000 was a loan from an investor who wanted to remain
anonymous. Petitioners’ reply brief filed with the Court further
contended that the $54,000 was a loan and not income. At trial
Mr. Wright claimed that the six $9,000 checks totaling $54,000
represented petitioners’ money, but stated: “I’m not saying they
came from previously reported income; I’m saying they are not
income.” Mr. Wright additionally stated that the $54,000 was
sent to Mr. Jones and then deposited by Mr. Jones into
petitioners’ Leadenhall account.23 Mr. Wright also claimed at
trial that he never opened a bank account at Leadenhall or
obtained a Mastercard credit card, which the Court did not find
convincing or credible.
Petitioners did not present any evidence to refute
respondent’s determination that the $54,000 was unreported
23Mr. Wright asserts that petitioners and Ms. Mohr entered
into asset management contracts with Mr. Jones that included a
best efforts 6-percent return and that Mr. Jones transferred the
money from those contracts to CLGs. The Court did not find Mr.
Wright’s testimony on this issue to be convincing or credible.
Furthermore, petitioners did not provide the alleged contracts or
any other evidence regarding such an agreement with Mr. Jones.
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