- 4 - of deficiency are presumed to be correct, and petitioner bears the burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Section 61(a) defines gross income to mean all income from whatever source derived including, but not limited to, compensation for services, including fees, commissions, fringe benefits, and similar items. Sec. 61(a)(1). Petitioner contends that the amounts he received from Florida Realty are not includable in his gross income because such amounts were reimbursements for amounts that he paid to maintain the Guilford rental property. Alternatively, he argues that, if such amounts are includable in income, he should be entitled to business expense deductions for the amounts that he advanced on behalf of Florida Realty. Petitioner further claims that he is entitled to business expense deductions for certain amounts he paid to wind up his law practice, subsequent to his disbarment. Petitioner has failed to meet his burden of proof. Rule 142(a). He did not comply with the requirements of the standing pretrial order. He has not shown good cause for his failure to exchange his documents with respondent as required by the pretrial order, and the Court did not receive them in evidence. His testimony was disjointed, contradictory, and, at times, incomprehensible.Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011