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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).
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Last modified: March 27, 2008