Bradley G. Bjelk - Page 10

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          worked at Jiordano's despite compelling evidence to the contrary,           
          without further explanation, undermines his credibility, and we             
          accordingly consider all of his other testimony with skepticism.            
          For 1992, petitioner also testified that he delivered a small               
          number of summonses for attorneys and was compensated for doing             
          so.                                                                         
               Thus, it has been demonstrated for the years 1988 through              
          1992 that petitioner was engaged in income-producing activities             
          in addition to those connected to the income determined in the              
          notices from identified sources.  Accordingly, respondent's                 
          determinations that petitioner had unreported income from                   
          unidentified sources in those years are presumptively correct,              
          and petitioner bears the burden of demonstrating that they are              
          erroneous.                                                                  
               With respect to 1993, however, there is no evidence that               
          petitioner was engaged in income-producing activity beyond his              
          work for Cantel Communications.  In the deficiency notice for               
          1993, respondent determined that petitioner received nonemployee            
          compensation from Cantel Communications in the amount of                    
          $18,018.98 and "unreported income" of $35,873.  Petitioner has              
          stipulated to the Cantel Communications income, but denies the              
          unreported income.  It has been stipulated that petitioner sold             
          the property where the Crazy Horse Saloon was located in 1991,              
          there is no evidence that petitioner worked as manager of                   
          Jiordano's beyond 1992, and there is no evidence that petitioner            




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