Hugh G. and Norma J. King - Page 17

                                       - 17 -                                         
          nontaxable transfer of receipts from their timber sales.  Mr.               
          King testified that he put receipts from timber sales before 1995           
          into their appliance business.  Mrs. King testified that money              
          from timber sales during the years in issue was deposited in                
          their farm account, and that she transferred it to the King’s               
          Appliances account as needed.  Petitioners did not state or                 
          provide any records showing how much money they transferred.                
               Petitioners contend that respondent failed to prove that the           
          $9,650 was from a taxable source.  Respondent linked petitioners            
          to several income-producing activities, and thus the deficiency             
          determination is presumed to be correct and petitioners have the            
          burden of proving that the $9,650 was from a nontaxable source.             
          See Blohm v. Commissioner, supra.  Petitioners did not do so.  We           
          conclude that petitioners had unreported cash income of $9,650 in           
          1995.                                                                       
               2.   Whether Respondent Correctly Determined Petitioners’              
                    Gross Receipts From Sales for 1996-97                             
               Petitioners dispute respondent’s determination that they had           
          unreported income from layaway sales in the amounts of $6,671 in            
          1996, and $467 in 1997.  Petitioners contend that the amounts               
          determined by respondent are greater than the amounts stated on             
          petitioners’ computerized general ledger which petitioners                  
          installed at respondent’s request.  However, the computerized               
          general ledger is not in the record, petitioners did not state              







Page:  Previous  7  8  9  10  11  12  13  14  15  16  17  18  19  20  21  22  23  24  25  26  Next

Last modified: May 25, 2011