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affg. T.C. Memo. 1984-601; Clayton v. Commissioner, supra;
Recklitis v. Commissioner, supra at 910. A taxpayer's
intelligence, experience, and other circumstantial evidence
relating to events in question may also be considered.
Niedringhaus v. Commissioner, 99 T.C. 202, 211 (1992);
Grosshandler v. Commissioner, 75 T.C. 1, 19-20 (1980).
Petitioner's records relating to funds he received from sale
of the S-J partnerships interests are inadequate. The evidence,
however, establishes that petitioner in 1976 received at least
$1,968,364 from sale of S-J partnerships interests. The evidence
establishes that petitioner exercised dominion and control for
his personal benefit over these funds. We conclude that the
evidence supports respondent's determination in the notice of
deficiency that petitioner received additional income in 1976 of
$1,968,364 from sale of partnership interests.
With regard to the $9,269,756 disallowed claimed S-J
partnerships losses, the evidence establishes that during 1976
the S-J partnerships did not enter into any mining agreements
with mining contractors, own any mining equipment, employ coal
operators, obtain rail siding to transport coal, or mine or sell
coal. The evidence establishes that the amount of coal reserves
on the property leased by the S-J partnerships was insufficient
to support a mining operation and that the funds received from
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