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 thatPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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