- 49 -
Apart from petitioner's general denial, we have not found
any evidence in the record that would contradict respondent's
determination on this point. Petitioner has failed to carry his
burden of proving error in respondent's determination.
We hold for respondent on this issue.
D. Summary
Taking into account our determinations, petitioner's income
or gross receipts were in the amounts shown in table 9. See
supra tables 3, 4, 5, and 6.
Table 9
Category 1982 1983 1984 1985 1986
Wages, etc. $46,943 $26,400 $24,000 -0- -0-
Interest 4,187 –- 4,419 $2,356 $2,297
Sched.C(gross rcpts.)94,713 1,095 1,000 13,448 3,565
Capital gain 8,207 21,600 -0- 40,000 --
Royalties 14,318 64,469 67,575 21,641 25,730
Other--
Farm (gross rcpts) 7,538 –- –- –- --
Rentals 15,026 1,000 –- –- --
Seismic fees 700 –- –- –- –-
Table 9 shows a general deterioration of petitioner's
economic condition during the period 1982 through 1986. This led
to petitioner's 1987 bankruptcy. Table 9 points up some
anomalies, such as an absence of interest income in 1983, but
that does not appreciably affect the general picture. We are
satisfied that table 9 is as good a representation of
petitioner's income or gross receipts as we can get, given the
limitations of the record and the parties' contentions in the
instant case.
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