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Date Check No. Amount Payee
04/06/89 1808 $395 1st Interstate
04/17/89 1816 1,702 1st Interstate
Total 2,097
Neither of these checks bears any notation, and the
peg
board ledger sheet on which these checks should appear was
not introduced into evidence.
OPINION
At the outset, we note that respondent concedes part
or all of four of the adjustments determined in the notice
of deficiency. First, with respect to the adjustment
increasing petitioners' income on the ground that
petitioner realized unreported income from H&B of $81,865
in 1988 and $36,762 in 1989, respondent concedes $5,700 of
the unreported income in 1988 and $5,500 in 1989. Second,
respondent concedes the full amount of the adjustment
charging petitioner with unreported rental income of $1,853
in 1989, and $979 in 1990. Third, respondent concedes, as
incorrect, the adjustment disallowing petitioners' capital
loss deductions of $3,000 per year in 1988 and 1989, and
$3,146 in 1990. Finally, respondent concedes the additions
to tax and penalties attributable to each of these conceded
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