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on Forms 1099, Miscellaneous Income, even though he knew he
received additional commissions.
1. Rental Business
Petitioner owned approximately eight residential rental
properties during each of the taxable years in issue. All rental
receipts, either in cash or by check, were deposited into
petitioner's account at American Commercial Bank in Ventura,
California (ACB account), the same account into which he
deposited income from other sources including his insurance
agency. For the taxable years at issue, petitioner had the
information available to him to maintain accurate records of his
correct rental income, but he failed to maintain accurate records
of the amount of rent he received. As summarized below and
stipulated by the parties, petitioner failed to report all of his
rental income for the years in issue:
Amount Rental Percentage of Rental
Reported Income Income Petitioner
Year on Return Received Failed to Report
1984 $25,560 $39,680 36%
1985 20,769 40,012 48
1986 21,613 48,742 56
1987 32,880 64,586 49
Petitioner submitted applications for loans to purchase
property during the years in issue in which he listed his income
as significantly greater than the amounts shown on his returns.
On petitioner's May 19, 1986, application for a loan to purchase
a property, petitioner included a statement that he received
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