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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.
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