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$106,037.66, and $232,028.76 on his 1982, 1983, and 1984 returns,
respectively. Respondent concedes $1,060.71 and $1,371.02 of
omitted income with respect to petitioner's 1982 and 1984
returns, respectively. Respondent also claims that petitioner
failed to report income that he received through Newtowne from
Saltergate I and Park Place in the amounts of $120,000 and
$180,000 on his 1982 and 1984 returns, respectively. Respondent
bears the burden of proof with respect to these claimed increased
deficiencies. Rule 142(a).
Petitioner does not deny that he received the amounts as set
forth in the findings herein. In any event, substantial evidence
was presented which leads us to the conclusion that petitioner
received the amounts of income claimed by respondent (as modified
by the Court). Petitioner asserts that the payments from
Newtowne originated with the partnerships and were either: (1)
Repayments to petitioner of loans he made to the partnerships or
(2) nontaxable partnership withdrawals.
We addressed petitioner's arguments in our discussion
regarding the unreported partnership fee income supra. In
holding that the payments petitioner received from the
partnerships were income, we found that there was no evidence in
the record which indicates that the amounts were: (1) Repayments
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