- 12 - Hale testified credibly that she had no knowledge of the checks. Petitioner offered no evidence concerning the dates of the undeposited checks and when they were received. We disagree with petitioner's contention that the day sheets are unreliable. Respondent's determination is presumed to be correct, and petitioner bears the burden of proving otherwise. Rule 142(a); Welch v. Helvering, 290 U.S. 111, 115 (1933). Petitioner has not proven that it did not have unreported income from its medical practice of $338,317 in fiscal year 1987 and $259,951 in fiscal year 1988. We sustain respondent's determination. C. Unreported Interest Income Petitioner received interest income of $1,333 in fiscal year 1987 and $5,189 in fiscal year 1988. Petitioner reported that it received interest income of $343 for fiscal year 1987 and zero interest income for fiscal year 1988. Petitioner does not deny that it received the interest income at issue. We conclude that petitioner had unreported interest income of $990 for fiscal year 1987 and $5,189 for fiscal year 1988. D. Net Operating Loss Section 172 allows a taxpayer to deduct net operating losses. Petitioner reported that it had a net operating loss ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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