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are sufficient to explain the self-employment income charged to
her for 1993.
Petitioner has shown nothing that justifies placing any
aspect of the burden of proof on respondent. Petitioner bears
the burden of proof. Petitioner’s only factual defense to
respondent’s adjustments increasing petitioner’s gross income is
that petitioner existed on gifts from her parents and
"significant other". We did not find petitioner to be a credible
witness concerning the sources of her income. On brief,
petitioner points us to one exhibit, Exhibit 16, “Funds Advanced
to Carolyn Fankhanel”, which, to the extent it addresses gifts to
her, was objected to by respondent and is not in evidence.
Beyond the conclusion to be drawn from petitioner’s admissions
that she received $5,000 from her father in 1983 and $2,000 from
her parents in 1984, petitioner has failed to prove the amount of
any gifts to her during the years in issue. She has failed to
prove any facts supporting her assignments of error with respect
to respondent’s adjustments increasing her gross income for any
of the years in issue. Respondent’s determinations of
deficiencies resulting from those adjustments are sustained.
III. Deduction for Personal Exemptions
A. Introduction
Respondent adjusted petitioner’s income by disallowing
personal exemption deductions claimed by petitioner for her son
Syme A. Kutz (Syme) for all of the years in issue and for her son
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