Robert E. Iles and Monica M. Iles - Page 55

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               Thus, (1) petitioners' gain on the transaction is $953 more            
          than the amount determined in the notice of deficiency, but (2)             
          because of the 60-percent exclusion, petitioners' adjusted gross            
          income from the transaction is $5,619 less than the amount                  
          determined in the notice of deficiency.                                     
               Petitioners failed to file a timely 1981 tax return.  In               
          fact, petitioners' 1981 tax return was filed after the notices of           
          deficiency were issued in the instant case.  In their late-filed            
          1981 tax return, petitioners acknowledged a tax liability of                
          $5,501.  Our findings show that petitioners' 1981 income subject            
          to tax is far greater than what they reported on their 1981 tax             
          return.                                                                     
               There is no indication of offsetting deductions or credits.            
               We conclude, and we have found, that respondent has shown by           
          clear and convincing evidence that petitioners had an                       
          underpayment of tax for 1981.                                               
               (3)  1982                                                              
               In the notices of deficiency for 1982, respondent determined           
          that petitioners had unreported income from (1) Random Processing           
          Services, Inc., (2) SSI, (3) the FE Trust, and (4) Maximum                  
          Management, and had unreported capital gain from the sale of SSC.           
               Pursuant to the parties' stipulation, we have found that in            
          1982 two checks totaling $15,000 were drawn on the Random                   
          Processing Services' bank account to Monica.  We have found that            





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