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address. There is no evidence to indicate whether the CRNA Trust
and the Family Trust are one in the same.
NAA filed 1991 and 1992 Federal tax returns, signed by
petitioner as general partner. On the Schedule K-1, Partner's
Share of Income, Credits, Deductions, Etc., attached to NAA's
1991 and 1992 returns, NAA reported the 1991 and 1992 income of
both the CRNA Trust and Oania as $80,505 and $72,130,
respectively. In the notice of deficiency, respondent determined
that petitioner failed to report income of $23,133 and $21,750
for 1991 and 1992, respectively. In respondent's second
amendment to answer filed on January 6, 1997, respondent
increased petitioner's 1991 and 1992 income tax by "50 percent of
$55,425" and "50 percent of $28,728", respectively. There is no
evidence to indicate that either the CRNA Trust or the Family
Trust ever filed returns or paid taxes for the years in issue.
OPINION
1. Unreported Income
Respondent determined that petitioner earned compensation
from his nurse anesthetic services that he failed to include in
gross income. Petitioner argues that the CRNA Trust earned the
disputed income, rather than he. We agree with respondent that
the compensation is taxable to petitioner.
Petitioner must prove that respondent's determinations set
forth in her notice of deficiency are incorrect. Rule 142(a);
Welch v. Helvering, 290 U.S. 111, 115 (1933); Potts, Davis & Co.
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