Prindle International Marketing, UBO, Keyus Group, Trustee - Page 16

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          $22,500 in 1992 and $28,200 in 1993.  There is no documentary               
          evidence to corroborate this testimony.                                     
               Petitioners cite two documents:  "QNC Contribution                     
          Instructions", which Mr. Fox signed on December 30, 1992, states:           
          "Contribution amount $100,000"; and "Collateralized Personal Line           
          of Credit Instructions", which Mr. Fox signed on December 30,               
          1992, states:  "Amount to be wired $85,000".  These documents do            
          not show that petitioners paid $100,000 in 1992 or at any time.             
               We conclude that petitioners may not deduct $100,000 in 1992           
          under section 419.                                                          
          D.   Whether Mr. and Mrs. Fox Had $2,237 in Unreported Interest             
               Income                                                                 
               Respondent determined and contends that Mr. and Mrs. Fox had           
          $2,237 in unreported interest income from Oxyfresh in 1993.                 
          Neither party offered any evidence on this issue.  Petitioners              
          contend that respondent has the burden of producing evidence                
          linking them to the unreported income, Weimerskirch v.                      
          Commissioner, 596 F.2d 358, 360 (9th Cir. 1979), revg. 67 T.C.              
          672 (1977), and that respondent failed to do so.  We agree with             
          petitioners.                                                                
               The U.S. Court of Appeals for the Ninth Circuit, the circuit           
          in which this case is appealable, requires the Commissioner to              
          introduce some substantive evidence that shows that the taxpayer            
          received unreported income.  United States v. Zolla, 724 F.2d 808           
          (9th Cir. 1984); Weimerskirch v. Commissioner, supra.  Oxyfresh             





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