-46-
Unreported Income--Interest
Respondent determined that petitioners failed to report
interest earned on their funds in the name of Shumin.
Petitioners have not presented any argument regarding
respondent's determination other than to assert, in response to
respondent's proposed finding of fact, that "respondent offered
no evidence on this issue."
Petitioners bear the burden of proving that respondent's
determination is incorrect. Rule 142(a). They failed to offer
any proof. Respondent's determination on this issue will be
sustained.
Schedule C Income--1990
Respondent determined that petitioners reported as income in
1991 funds that they received in 1990, including approximately
$34,544 from Kortava for the business school and $38,000 from
Kortava for the vehicle resale business. Petitioners exercised
complete dominion and control over these amounts and, as such,
have gross income in the amounts we conclude below. See James v.
United States, 366 U.S. 213, 219 (1961).
Business School
Petitioners have conceded that the proper year for reporting
the business school income is 1990, but petitioners have not
conceded the amount of income that should be reported.
Petitioners have not presented argument or evidence to show that
the amount of respondent's determination, $34,544, is incorrect.
Thus, respondent's determination that petitioners' 1990
Page: Previous 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 55 NextLast modified: May 25, 2011