- 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.Page: Previous 33 34 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 Next
Last modified: May 25, 2011