- 24 - argues that the evidence shows that the Michoff, Srs., freely transferred moneys and property between themselves and Michoff, Jr., and that Michoff, Jr., was involved in the sale of drugs during this period, which resulted in substantial income to himself and to his family, including the Michoff, Srs. Respondent contends that the Michoff, Srs., received money from Michoff, Jr., from his drug business but offers no explanation of why this would be taxable to the Michoff, Srs. We conclude that this is not a taxable source of income to the Michoff, Srs. Respondent did, however, analyze the bank deposits and expenditures of the Michoff, Srs., to determine the amount of unreported income. Petitioners have failed to prove that any of the disputed amounts are from nontaxable sources. Respondent is sustained on this issue. Casualty Losses and Telephone Expenses The Michoff, Srs., claimed miscellaneous itemized deductions for alleged job required phone usage in the 1989 and 1990 tax years in the amounts of $264 and $394, respectively. The Michoff, Srs., admitted on brief that no evidence was provided to establish the deductions claimed for the alleged job required phone usage. Petitioners failed to meet their burden of proof, and therefore respondent's determination regarding the deductions for phone usage is sustained. The Michoff, Srs., claimed itemized casualty loss deductions for the 1989 and 1990 tax years in the amounts of $3,965 andPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
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