- 4 -
OPINION
I. Unreported Income
Respondent's notice of deficiency is presumed to be correct,
and the taxpayer bears the burden of proving that it is
erroneous. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115
(1933). Gross income includes all income from whatever source
derived. Sec. 61(a). Interest income and proceeds from the sale
of stock constitute gross income. Sec. 61(a); secs. 1.61-6(a);
1.61-7(a), Income Tax Regs.
Respondent contends that petitioner failed to report $131 in
interest income and $104,147 in proceeds from the sale of stock.
Petitioner contends that the Internal Revenue Service has
orchestrated a campaign of harassment and false allegations
against him. He, however, failed to present any evidence to
refute respondent's determination and, as a result, has failed to
carry his burden of proof relating to this issue. Accordingly,
we conclude that petitioner received $104,278 of unreported
income in 1989, and the deficiency determined by respondent is
sustained.
II. Addition to Tax for Failure To File a Timely Return
Section 6651(a)(1) imposes an addition to tax for failure to
file a timely return, unless it is shown that such failure is due
to reasonable cause and not due to willful neglect. Petitioner
bears the burden of proving that his failure to file a timely
Page: Previous 1 2 3 4 5 Next
Last modified: May 25, 2011