Bifalgorithm post · Fuscalite · B. Adverse Inference

Loan Reconciliation

Loan Reconciliation (Fuscalite · B. Adverse Inference) — "With respect to the reconciliation that was prepared, the Tax Court Judge noted, at page 15 of the tr…

Ideas in this flowchart

The Tax Court Judge assessed the reconciliation as unreliable and damaging to Mr. Deyab’s credibility.
The assessment appears at page 15 of the transcript of the Judge’s oral reasons.
The document purports to provide a detailed reconciliation of the corporation’s shareholder loan account.
The reconciliation does not reflect the substantial withdrawals exceeding $2 million that are at issue in the appeals.
The omission makes the document unreliable in the Judge’s view.
The Judge placed little weight on the document.
The document critically undermines the credibility of Mr. Deyab’s testimony.
The document also critically undermines Mr. Deyab’s assertions.

Bifalgorithm

Feed/

Loan Reconciliation

No cover

Channel

Fuscalite

1 page

USR292600b83e2a

Ebook1w

"With respect to the reconciliation that was prepared, the Tax Court Judge noted, at page 15 of the transcript of his oral reasons:\n\nWhile it purports to provide a detailed reconciliation of the corporation’s shareholder loan account, I note that it critically does not reflect the substantial withdrawals in excess of $2 million that are at issue in these appeals. As a result, it is my view that this document is unreliable, and I have placed little weight on it. As discussed further below, it is my view that this document also critically undermines the credibility of Mr. Deyab’s testimony and his assertions."

Flowchart preview

👍

0 comments0 shares