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vein, petitioner credibly testified that he acted as an agent for
Mr. Stennett and the Vanderhaydens because he was "trying to help
a fellow breeder * * * and trying to promote a breed of cattle that
[he] thoroughly believed in". Nonetheless, petitioner failed to
convince us that the amount of unreported gross receipts for the
years in issue, as stipulated,6 included cash payments he made to
the Vanderhaydens and/or Mr. Stennett (and others) as agent for
others. Further, petitioner failed to show that other than the
amount by which petitioner's cattle-breeding receipts were reduced
to reflect amounts petitioner paid to the Vanderhaydens and Mr.
Stennett (the Cattle Company) by check, respondent was aware of
cash payments to them in reconstructing petitioner's income. Mr.
Stennett as well as Marion Vanderhayden testified that in examining
their books and records, they could not differentiate which of the
payments they received from petitioner represented payments for
cattle petitioner purchased from them for his own operation, and
which represented proceeds from sales to others in which petitioner
acted as their (the Vanderhaydens' or Mr. Stennett's) broker.
Petitioner's lack of records, as well as the skimpy record before
us, inhibit us from further reducing the stipulated unreported
6 The stipulated amount of petitioner's cattle-breeding
gross receipts was reduced to reflect: (1) Amounts petitioner
paid the Vanderhaydens by check as follows: 1991--$14,241, 1992--
$1,500, and 1993--$700; and (2) amounts petitioner paid Mr.
Stennett (The Cattle Company) by check as follows: 1992--
$1,450.23, and 1993--$12,500.
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