- 53 - Wire Wire Wire Wire transfers to transfers to transfers transfer to SSI for the operate the for family Tax purchase development Rivercliff support year Rivercliff of Rivercliff1 farm2 obligations3 1998 $519,033 $249,193 $36,263 -0- 1999 -- 2,109,464 -0- -0- 2000 -- 2,746,708 -0- $12,000 2001 -- 274,953 13,454 8,670 2002 -- -0- 42,533 181,765 Total 519,033 5,380,318 92,250 202,435 1 The wire transfer to SSI in 1998 of $249,193 for the development of the Rivercliff property was from TPPL. The wire transfers for the development of the Rivercliff property in 1999, 2000, and 2001 were from NCPL. 2 Using the bank deposits method to reconstruct petitioner’s income, respondent found that petitioner failed to report income of $36,263, $13,454, and $42,553 in 1998, 2001, and 2002, respectively. Petitioner asserted these amounts were loans for the operation of the farm on the Rivercliff property. 3 Petitioner’s family support obligations include the total amounts NCPL wire transferred to petitioner for his spousal and child support obligations in 2000, 2001, and 2002 and for the interest paid on the $1,400,000 divorce settlement in 2002. Petitioner does not dispute the amounts of the wire transfers but contends the transferred funds comprised three nontaxable loans for: (1) The purchase of the Rivercliff property; (2) the development of the Rivercliff property and the operation of the farm on the property; and (3) petitioner’s spousal and child support obligations and the interest paid on the $1,400,000 divorce settlement (petitioner’s family support obligations).Page: Previous 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 NextLast modified: March 27, 2008