Bradley G. Bjelk - Page 17

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          to meet the cost of living of petitioner and his family.  We                
          conclude on this record that respondent's determination of                  
          unreported income of $30,492 is erroneous.  We accordingly                  
          sustain respondent's determination of unreported income only to             
          the extent of $20,902.  In addition, since we have found that               
          petitioner paid home mortgage interest of $6,242 in 1989,                   
          petitioner is entitled to a deduction in that amount, although              
          respondent's allowance of the standard deduction in the notice of           
          deficiency must be adjusted accordingly.  Petitioner has not                
          substantiated any other Schedule A deductions.                              
          1990                                                                        
               The parties have stipulated that petitioner received                   
          nonemployee compensation of $1,035 from J&K Developers, Inc., in            
          1990.  It has also been stipulated that petitioner operated the             
          Crazy Horse Saloon "during 1990".  Petitioner testified that he             
          ceased operations on July 1, 1990.  Other evidence in the record            
          provides some support for this assertion.9  In a personal                   
          financial statement dated March 29, 1990, submitted to a bank to            
          obtain a loan, petitioner represented that his annual income was            


               9 The parties have stipulated that the Crazy Horse property            
          was sold in 1991 and have not stipulated that any operations were           
          conducted in that year.  The only liquor license granted to the             
          Crazy Horse Saloon that is in evidence carries an expiration date           
          of Apr. 30, 1990.  No State tax returns for the business beyond             
          1989 are in evidence.  The parties have stipulated that                     
          petitioner paid mortgage interest related to the Crazy Horse                
          property of $4,360 in 1990, which is less than half the amount              
          paid in each of the 2 preceding years.                                      




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