Carolyn M. Fankhanel - Page 15

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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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