Robert D. Grossman, Jr. - Page 63

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          category.  Petitioner failed to carry his burden of proving that            
          respondent erred in determining that the remaining $12,759.63               
          constitutes unreported constructive dividend income to Betsy.               
               In supra table 12, we set forth our conclusions that                   
          $8,173.56 of the disputed 1986 amounts were constructive                    
          dividends to Betsy, that $160.22 were Sley Corporations’ business           
          expenses, and that we could not find that the remaining $3,325.84           
          of disputed Markette payments fit into either category.                     
          Petitioner failed to carry his burden of proving that respondent            
          erred in determining that the remaining $3,325.84 constitutes               
          unreported constructive dividend income to Betsy.                           
               We hold for respondent on this issue, except that we hold              
          for petitioner as to $90 for 1985 and as to $160.22 for 1986.               
          B. Interest Deduction                                                       
               Respondent contends that petitioner’s and Betsy’s 1987 joint           
          tax return overstated an itemized personal interest deduction by            
          $8,559.  Petitioner contends that the interest deduction was                
          properly taken for 1987.  The deduction in issue stems from the             
          $13,167.96 interest payment Betsy made to Markette.                         
               We agree with respondent’s conclusion.                                 












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