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Stevenson, there is no evidence of this payment on the CTC
receipts journal, and there is no other evidence presented by
either party. Petitioner merely states in a proposed finding of
fact pertaining to it that his accountant had reviewed all
commissions received by CTC and petitioner for the pertinent
years, and petitioner had reported all income. Respondent does
not address this amount on brief. We assume that respondent has
conceded this issue and hold for petitioner.
With regard to the alleged "unreported income" in the amount
of $1,478.31 from Stewart & Stevenson in 1976, neither party
presented any evidence. In a proposed finding of fact petitioner
implies that it was paid directly to Diesel Power. Whether it
was or not, we hold for respondent with respect to this amount.
If it was paid to Diesel Power, it was petitioner's income for
the reasons stated above; if it was not paid to Diesel Power,
petitioner has failed to meet his burden of proof that it was not
his income. Rule 142(a).
With regard to the allegation of income from IMICO, SEDIRAN,
and SEDCO in 1978, the parties presented no evidence other than
the 1978 receipts journal. We note that, while the 1978 CTC
receipts journal lists numerous receipts from IMICO, SEDIRAN, and
SEDCO in that year, the receipts are all recorded as either
"Purchases" or commissions to CTC, the latter having been
reported by petitioner as income. As to the amounts for 1978,
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