Ramon and Irma Ortiz - Page 14

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               E.  License Use                                                        
               Petitioners assert that $39,163 of their unexplained                   
          deposits for 1992 is attributable to salesmen's use of Mr. Ortiz'           
          license to purchase automobiles.  They argue that only money                
          attributable to the $100 fees that Mr. Ortiz charged the salesmen           
          for each car purchased using this license should be taxed.                  
          However, petitioners failed to substantiate any of these                    
          salesmen's purchases and provided no information indicating how             
          many $100 fees they received.  Petitioners also failed to show              
          that money received from any such transactions was deposited into           
          either of the bank accounts.                                                
               F.  Conclusions as to Unreported Income                                
               In sum, we hold that Mr. Ortiz had unreported self-                    
          employment income from his wholesale used car business of $17,390           
          in 1991 and $49,163 in 1992. Petitioners had unreported interest            
          income of $18,000 in 1991 and $4,000 in 1992.                               
          Issue 2.  Additional Interest Income                                        
               We hold that petitioners did not receive additional interest           
          income of $3,500 in 1991 and $3,000 in 1992.  These amounts are             
          included in the interest payments petitioners have conceded they            
          received from Mr. Rodriguez.  See supra Issue 1D.                           
          Issue 3.  Capital Loss for 1991                                             
               Under section 1211 a taxpayer other than a corporation is              
          limited to $3,000 in net capital losses in any given tax year.              






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