- 10 -
by petitioner as part of his presentation of the sequence of
events pertaining to his litigation travails. The contents of
that document are disputed by petitioner and are pure hearsay.
Ms. Michell was not called as a witness to support its contents,
and it does not lend persuasive support to respondent’s
determination. Thus, in view of petitioner’s credible denial
that he received such interest, we hold that petitioner did not
receive any taxable interest income from his attorney or any
trust in 1993.
Respondent also determined for the 1993 year that petitioner
earned Schedule C income of $3,750 resulting from the preparation
of 25 tax returns at $150 per return. We conclude, based upon
petitioner’s testimony, that petitioner had $2,000 of Schedule C
income, resulting from the preparation of 10 tax returns at $200
apiece. Petitioner has failed to present any books and records
of his 1993 tax preparation business. Accordingly, he has failed
to prove which of his clients, if any, failed to pay his fee. In
addition, petitioner claims that he had legitimate business
expenses to offset that income. However, he has failed to
substantiate any business expenses. While our conclusions herein
result in no taxable income for petitioner for 1993 (as
petitioner’s income for the year is less than the combined amount
of his personal exemption and standard deduction), petitioner
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011