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that the taxpayer had unreported income. Gold Emporium, Inc. v.
Commissioner, 910 F.2d 1374, 1378 (7th Cir. 1990), affg. Malicki
v. Commissioner, T.C. Memo. 1988-559.
Respondent has established, except with respect to 1993,
that petitioner was engaged in income-producing activities beyond
those that can be attributed to the income from identified
sources to which petitioner has stipulated. For taxable years
1988, 1989, and 1990, petitioner has stipulated that he operated
a business known as "The Crazy Horse Saloon" (the Crazy Horse
Saloon) and has admitted receiving income from this business in
each year, although in lesser amounts than respondent determined
as unreported income.
With respect to 1991 and 1992, we are satisfied that the
evidence establishes that petitioner worked as manager of
Jiordano's Pizza (Jiordano's) in Dekalb, Illinois. Petitioner
denied that he ever worked at Jiordano's, even when confronted
with 1991 and 1992 DeKalb telephone directories listing him as
the manager of the establishment. Moreover, respondent produced
a witness who was a cable television installer and who testified
that he made an installation at Jiordano's in 1991 or 1992, that
petitioner was listed as the contact person on the work order for
such installation, that petitioner and his sons were the only
persons present in the establishment and they entered areas not
normally accessible to customers, and that petitioner paid for
the installation. In our view, petitioner's denial that he
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