- 43 -
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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