- 3 - which we so find. The stipulations of fact filed by the parties and attached exhibits are incorporated herein by this reference. Although the issues remaining for decision are principally factual, we need find few facts in addition to those stipulated by the parties. Accordingly, we have not divided our report into two sections, one comprising our findings of fact and the other setting forth our opinion. The additional findings we must make are contained in the discussion that follows. After setting forth certain background information, we shall address (1) the adjustments made by respondent that remain in dispute and (2) the additions to tax that remain in dispute. Petitioner bears the burden of proof on all questions of fact. Rule 142(a). I. Background Petitioner resided in Huntington, New York, at the time the petition in this case was filed. During 1986, petitioner was employed as an automobile salesman by two different automobile dealerships, Sports Imports Inc. (Sports Imports) and Rallye Motors, Inc. (Rallye Motors). Petitioner was unemployed from approximately April 1986, when his employment by Sports Imports ended, until December 1986, when his employment by Rallye Motors began. During 1987 and 1988, petitioner was employed as an automobile salesman by Rallye Motors. During 1987 and 1988, petitioner owned a horse racing and breeding business. Petitioner is a frequent gambler.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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