- 18 -
$20,000, which is an admission. In connection with divorce
proceedings on August 28, 1990, petitioner signed a separation
agreement representing that his annual income was $18,000 and
testified under oath that his current occupation was "machine
operator". Yet on a 1990 Federal income tax return completed and
signed by petitioner and submitted in support of his position at
trial, he states that his gross income for 1990 was $5,535,
consisting of the $1,035 in compensation from J&K Developers and
an estimated net profit of $4,500 from the Crazy Horse Saloon.10
Petitioner has not accounted for his admitted $20,000 or $18,000
annual income in 1990 or, with the possible exception of the
income from J&K Developers, any income from his work as a machine
operator. We do not believe that gross income of $5,535 was
sufficient to meet petitioner's cost of living, even accepting
his contention that he lived with his mother during 1990. We
note in this regard that petitioner assumed child support
obligations of $100 per week, plus one-half of medical expenses,
as well as a $2,000 debt, in the divorce proceedings. We
conclude that no error has been demonstrated in respondent's
determination of $32,285 in unreported income for 1990 and
accordingly sustain it.
1991
10 Petitioner reported only a net profit figure on Schedule
C of the submitted 1990 return, without a supporting computation,
adding the notation that the figure represented one-half of his
net profits from the business in the preceding year.
Page: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 NextLast modified: May 25, 2011