- 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 of
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011