- 8 -
consideration the transfers pointed out by petitioners and
reduced the adjustment for gross receipts.
Petitioners argue that the gross receipts adjustment for
2002, even as adjusted for transfers, is incorrect because it
does not take into consideration deposits of loan repayments from
Mrs. Runels’s friend, Leta Edar (Ms. Edar), and gifts from her
father, Juan L. Valdivieso. Mrs. Runels testified that she also
deposited into the bank accounts expense reimbursements from her
job of amounts she expended at Costco. She provided no evidence,
however, other than her own vague testimony, that reimbursements
by her employer may have been deposited.
Petitioners offered a typewritten statement dated September
1, 2005, from Mrs. Runels’s father3 to the effect that he had
given petitioners “several thousands of dollars in monetary gifts
in the year 2002.” Petitioners offered no details as to either
the amounts or timing of the alleged gifts or when they were
deposited, if at all.
According to Mrs. Runels’s testimony, she lent Ms. Edar
$6,000 for which she received no promissory note, maintained no
written record of repayment, and received repayments only in cash
for which she never provided a receipt. She testified that Ms.
Edar “still owes me $400”; she added that “This is just a friend
helping a friend.”
3Juan Luis Valdivieso passed away on December 5, 2006.
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: March 27, 2008