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Taxable Income Tax Additions
Year Deficiency To Tax
1986 $11,062.00 $3,300.73
1988 3,927.00 1,234.37
1989 43,131.00 13,699.70
1990 20,276.00 6,396.52
1991 19,610.00 6,023.24
1992 9,182.00 2,695.96
Respondent also informed petitioner at the hearings that
further adjustments would be made if petitioner demonstrated
nontaxable sources of income and/or business expenses in excess
of those underlying respondent’s revised computations, provided
evidence of a cost basis in property generating capital gains, or
substantiated certain amounts claimed as itemized deductions.
Petitioner did not do so, and respondent’s position regarding
petitioner’s tax liabilities remained substantially unchanged at
the time of trial on March 21, 2001. Petitioner appeared and
testified at trial but did not provide any further documentation
relating to his financial affairs. Subsequent to the
proceedings, respondent filed a posttrial brief; petitioner did
not.
II. Net Income From Proprietorship
The income of a sole proprietorship must be included in
calculating the income and tax liabilities of the individual
owning the business. Sec. 61(a)(2). The net profit or loss of
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Last modified: May 25, 2011