- 5 -
1986 Pantera -- 22,445 --
4120 Eierman Ave. -- -- 1$10,558
Rt. 40 West Furniture -- -- 2,196
1984 Lotus -- -- 13,185
1984 Porsche Cabriolet -- -- 5,000
Totals 17,774 179,209 30,939
1 The amount shown as expended for this property has been1
adjusted to reflect the agreement of the parties.
With respect to certain of those items, the statement of
facts recites that petitioner used his mother, Dolores Bruno, as
a nominee to disguise his purchases.
The District Court accepted petitioner’s guilty pleas and
entered verdicts of guilty. Subsequently, the District Court
entered a judgment in accordance with its verdicts and sentenced
petitioner to imprisonment for 97 months.
Petitioner made returns of income for each of the years in
issue, but reported no income from his illegal drug activities.
Respondent’s determination of deficiencies in tax for the
years in question is, principally, the result of respondent’s
adjusting petitioner’s gross income for each year to include
amounts equal to petitioner’s expenditures for the listed
property.
Discussion
I. Preliminary Matter
The general rule is that the burden of proof is upon
petitioner, Rule 142(a), which he must carry by a preponderance
of the evidence, e.g., Schaffer v. Commissioner, 779 F.2d 849,
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Last modified: May 25, 2011