- 10 -
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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