- 10 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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