- 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 petitionerPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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