Kim Beauchamp - Page 13

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          Commissioner, 994 F.2d 1542, 1549 (11th Cir. 1993), affg. T.C.              
          Memo. 1991-636 (once the Commissioner made a minimal evidentiary            
          showing, the deficiency determination was presumed correct).                
          Respondent's analysis of petitioner's bank deposits and                     
          petitioner's concession that he did not report income of $44,405            
          and $58,669 for 1989 and 1990, respectively, connect petitioner             
          with the funds forming the basis of the deficiency.  The burden             
          of proof, therefore, lies with petitioner to show error in                  
          respondent's determinations.  See Schad v. Commissioner, 87 T.C.            
          609, 620 (1986), affd. without published opinion 827 F.2d 774               
          (11th Cir. 1987) (connecting the taxpayer with the funds that               
          form the basis of the deficiency is sufficient to give him the              
          burden of proving the deficiency determination erroneous).                  
               Petitioner did not present any evidence or argument, other             
          than that respondent bears the burden of proof, to prove that he            
          did not omit from income any of the cash or checks listed in the            
          schedules of omitted income, or that these funds were not taxable           
          income, during the years in issue.  Petitioner has not met his              
          burden; therefore, we find that petitioner had unreported income            
          in the amounts of $50,292, $58,971, and $67,488 for 1988, 1989,             
          and 1990, respectively.                                                     
          Mortgage Interest, Property Tax, and Real Estate COGS                       
               Petitioner claimed deductions for mortgage interest and                
          property taxes paid relating to Ms. Choe's properties on his                
          Schedule A and claimed as costs of goods sold the expenditures              



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