Wilburn C. Hall, Jr. - Page 35

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        cited therein; see also Erickson v. Commissioner, 937 F.2d 1548,              
        1552-1553 (10th Cir. 1991), affg. T.C. Memo. 1989-552.                        
        A. Schedule C Income--1982                                                    
        Petitioner contends that he reported all income that was                      
        known to him, and that any difference between expenses and                    
        revenue came from loans or from disinvestment, e.g., sales of                 
        assets. Petitioner also claims that on December 31, 1981, he had              
        a net worth of more than $1 million, and points out that by 1987              
        he was bankrupt.                                                              
        Respondent contends that petitioner received and omitted                      
        Schedule C income for 1982 in the amount of $185,512. See supra               
        table 4, for a comparison of respondent's determinations in the               
        notice of deficiency and respondent's position on brief.                      
        We agree in part with respondent and in part with                             
        petitioner.                                                                   
        (1) Background                                                                
        When petitioner filled out his tax returns for the years in                   
        issue (supra table 2), he did so by using his memory, estimating              
        figures, and looking at old check registers and assorted                      
        receipts. Petitioner did not keep his records in an organized                 
        manner. About 4 months after petitioner filed his 1982 tax                    
        return, and just after he filed his 1986 tax return, in January               
        1988, some of petitioner's records were inadvertently shipped                 
        away. In June 1989, petitioner brought three boxes of unsorted                
        records to Burns' office, but was told to take them back and sort             




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