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admissions fail to disclose exactly how much of that amount he
received in 1976 as opposed to 1977, or how much he failed to
report in 1976. Petitioner's deemed admissions do not allocate
his commission income between 1976 and 1977, the years when
petitioner admits that he sold interests in the S-J partnerships.
The record before us on this motion does not include detailed
information concerning petitioner's other or miscellaneous income
for 1976. Consequently, while the record indicates that
petitioner failed to report commission income in 1976, respondent
has not made a prima facie showing of the amount of such income
that petitioner failed to report that year.
As for taxable years 1977 and 1978, in 1984 petitioner filed
documents with the Internal Revenue Service which purported to be
Forms 1040 for those earlier years. On line 20 of his purported
1977 Form 1040, petitioner reported other income in the amount of
$2,000,536. On line 20 of his purported 1978 Form 1040,
petitioner reported other income in the amount of $2,926,612.
Respondent determined that petitioner had failed to file returns
for 1977 and 1978, and therefore that petitioner had failed to
report other or miscellaneous income for those years in the
respective amounts of $2,000,536 and $2,926,612.
With respect to the amount of petitioner's other or
miscellaneous income, the relevant portions of the record for
1977 and 1978 are as follows. Petitioner contends in his
petition that respondent's determinations of additional taxable
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