Bradley G. Bjelk - Page 15

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          property and a basis of $55,550.  Petitioner has provided no                
          substantiation of the claimed sales expenses.  With respect to              
          the claimed basis, we observe that respondent offered into                  
          evidence two personal financial statements dated December 31,               
          1987, and February 16, 1989, that petitioner submitted to a bank            
          to obtain loans.  In both statements, petitioner represented that           
          the property at the 11th Street address was acquired in 1983 at a           
          cost of $57,000.  We find sufficient corroboration that                     
          petitioner had a basis in the property of at least $55,500.  We             
          accordingly find that his net gain on the sale of the 11th Street           
          property was $13,950 ($69,500 gross sales price less $55,550                
          basis).  We therefore sustain respondent's determination of                 
          income from real estate sales in the amount of $13,950 only.                
               It is stipulated that petitioner continued to operate the              
          Crazy Horse Saloon in 1989.  With respect to his income from this           
          business, petitioner filed returns for retailers' occupation and            
          related taxes for the Crazy Horse Saloon with the Illinois                  
          Department of Revenue, in which he reported total receipts for              
          1989 of $30,591.  This figure was also represented by petitioner            
          as his gross receipts from the Crazy Horse Saloon on Schedule C             
          of the 1989 Federal income tax return previously noted.  Both               
          representations of gross receipts constitute admissions by                  
          petitioner.  Petitioner listed various deductions on the Schedule           
          C in computing net profit from the Crazy Horse Saloon, but has              
          provided no substantiation for any of them except mortgage                  




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