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during 1992, 1993, 1994, and a portion of 1995 as a contract
electrical technician and that he was paid for that work during
those years; (2) that he owned certain rental property during
1992, 1993, 1994, and 1995 and that he received rent thereon
during those years; (3) that during 1993 he received $6,500 of
unemployment compensation; (4) that during 1993 he received a
dividend of approximately $40; and (5) that during 1995 he sold a
rental property that he and his father had purchased in 1983.
The record establishes that petitioner received income during the
years at issue, and we reject petitioner's position that respon-
dent's income determinations are arbitrary. Nonetheless, we are
persuaded by the record before us that petitioner does not have
long-term capital gain and rental income for 1995 in the amounts
determined by respondent.
With respect to respondent's determination that petitioner
has long-term capital gain for 1995 in the amount of $103,500,
respondent acknowledges that a Form 1099-S (Proceeds From Real
Estate Transactions) that was issued to petitioner's father, Owen
Buske, reflected the proceeds received during 1995 from the sale
of certain rental property and that, based on third-party infor-
mation, petitioner was co-owner of that rental property (co-owned
rental property). However, because petitioner did not provide
respondent with information establishing the extent of his co-
ownership of, and his basis in, the co-owned rental property,
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