Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 35

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               We have considered petitioners' arguments regarding all                
          other deposits that are in dispute and consider them to be                  
          without merit.  Petitioners have failed to carry their burden of            
          proving a nontaxable source with respect to the disputed deposits           
          and expenditures.  Therefore we hold that respondent is sustained           
          on this issue.                                                              
          Capital Gains from the Sale of a Partnership Interest in 1986               
               Prior to the years in issue, Michoff, Jr., had a 50-percent            
          partnership interest in Michaels & Michaels Autobody Shop (the              
          autobody shop).  At the beginning of 1986, Michoff, Jr., disposed           
          of half of his partnership interest in the autobody shop,                   
          retaining a 25-percent interest.  The parties stipulated that the           
          amount of capital gain from that disposition was $30,644.                   
          Respondent determined that Michoff, Jr., failed to report this              
               Despite these stipulations, Michoff, Jr., argues that he had           
          no gain from the sale of his partnership interest.  Michoff, Jr.,           
          offered no documentary evidence to disprove respondent's                    
          determinations and chose instead to rely on unsubstantiated                 
          claims on brief.  Michoff, Jr., has failed to meet his burden of            
          proof.  We therefore sustain respondent on this issue.                      
          Limousine Activity                                                          
          In her notice of deficiency, respondent disallowed Schedule C               
          deductions claimed by Michoff, Jr., on his 1989 income tax return           

          he claims to have sold on or prior to Mar. 26, 1990.                        

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