Albert J. and Helen R. Desantis - Page 43

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               Total                                      $380,132.74                 
               (c)  Unreported Income From Savko and Schedule C Oil                   
          and Gas Income                                                              
              With respect to respondent's determination that petitioner             
          received unreported income from Savko in 1983 and 1984,                     
          petitioner has not met his burden of proving that respondent's              
          determination is erroneous.  No evidence or argument was                    
          presented that the amount petitioner received from Savko in 1983            
          or 1984 does not represent taxable income.  In addition,                    
          petitioner has not met his burden of proving that respondent's              
          determination erroneously disallowed a deduction for windfall               
          profits tax withheld in 1982, relating to petitioner's oil and              
          gas exploration business.  Accordingly, respondent's                        
          determinations are sustained.                                               
               (d)  Uncollectible Operating Expenses in 1984 and the                  
               Adjustment to Gross Receipts                                           
               As indicated, respondent's notice of deficiency determined             
          that petitioner was not entitled to a claimed bad debt deduction            
          in the amount of $2,516,224, purportedly attributable to                    
          "Uncollectible operating advances".  Petitioner, however, has               
          failed to produce any evidence of loans related to the claimed              
          bad debts.  Accordingly, we sustain respondent's determination.             










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