- 20 - explanation for each adjustment that respondent made, and they identify the amounts of tax, interest, and penalties due. Petitioners have only themselves to blame for their difficulties in these cases. They had many opportunities to exchange evidence with respondent as required by our orders. Petitioners seemed to think that insulting respondent's agents would enhance their chance of prevailing and excuse their failure to take steps necessary to fully present their cases on the merits. C. Whether Respondent's Determination Should be Sustained 1. Whether Petitioners Had Less Income Than Determined by Respondent Petitioners contend that they had less income than respondent determined. Mr. Owens testified generally that the Big O businesses did not generate as much income as respondent determined, and that the Big O businesses were small and competed with larger firms. He did not give any information to support his conclusionary claims. Mrs. Owens testified briefly. Her testimony did not show that respondent's determination was incorrect. Ms. Feltrinelli did not testify. We sustain respondent's determination about the amount of income petitioners received in 1989 and 1990, except as conceded by respondent.Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
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