- 14 - concerning a certain credit, which was passed through to the trusts from a partnership called Traylor Syndicate (Traylor). It was this credit, according to petitioner, which paved the trail to the Cynwyd Group. We do not see how. Logically, the next tax returns that petitioner should have examined were those of Traylor, through which the credits passed to the trusts. However, the next returns which petitioner did, in fact, examine were those of Cynwyd Investments and Saligman Capital. Yet, the trusts were not partners in either of those partnerships. We find no basis for petitioner’s extension of his investigation to include the Cynwyd Group, other than that he was paid by Toll to do so. Accordingly, we disregard petitioner’s testimony. Petitioner offers little other evidence to aid him in meeting his burden of proof. We find, therefore, that petitioner has failed to carry his burden of proving that he did not receive unreported bribe income of $105,000 in 1980 and $7,500 during 1982 and 1983. Additionally, petitioner has not shown that respondent’s method of allocating the $7,500 equally between 1982 and 1983 is unreasonable. Harbin v. Commissioner, 40 T.C. at 377. Accordingly, we sustain respondent’s deficiency determinations. II. Additions to Tax for Fraud Respondent determined that petitioner is liable for additions to tax for fraud under section 6653(b) for 1980, and section 6653(b)(1) and (2) for 1982 and 1983.Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
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