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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.
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