4
(1988). It applies to issues of fact, issues of law, and mixed
issues of fact and law. Id. at 283.
The taxable year 1987 was at issue in Johnson I, and that
opinion was based in part on petitioner's failure to meet his
burden of proof. We have concluded that the issues now before
the Court were not necessarily litigated in Johnson I.
Petitioner, in this proceeding, could prove different facts or
changed circumstances sufficient to distinguish this case from
Johnson I and to carry his burden of proof for the years at
issue.
Petitioner resided in Vernon, Connecticut, at the time he
filed the petition. He has a bachelor's degree in mathematics
and a master's degree in psychology. Petitioner received
training as an actuary and has consulted as a stock analyst.
Petitioner did not receive salary or wages in 1988. Petitioner
has prepared his own income tax returns since 1981, and he
reported his income and deductions for the taxable years 1988 and
1989 on the cash receipts and disbursements method of accounting.
Ticketline
In 1985, petitioner began purchasing concert tickets from
Robert Finnimore (Finnimore) through a business known as
Ticketline. Finnimore purchased tickets to concerts, plays, and
other events and then resold the tickets at a premium.
Finnimore needed cash to purchase tickets, so petitioner
agreed to advance money to Finnimore, with the understanding that
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