Richard A. Cole, M.D. Inc. - Page 12

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          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 of            










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