Ronald B. and Annette C. Talmage - Page 53




                                        - 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).                








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