- 26 - returns, petitioners reported the following amounts of total tax: Petitioner 1982 1983 Giongo $4,360 $3,343 Wilson 22,178 5,722 Cattalo 2,932 2,326 Grove 6,158 4,599 Wilson reported net gain from the sale of stock in the amounts of $66,633 and $3,919 for 1982 and 1983, respectively. Respondent's Determinations Using the specific items method, respondent determined that petitioners had additional gross receipts as follows: Petitioner Taxable Year 1982 Taxable Year 1983 Ryan $94,650 $159,650 Giongo 93,300 121,600 Wilson 94,650 126,650 Cattalo 94,650 167,150 Grove 95,731 177,150 Respondent granted each petitioner's spouse innocent spouse status as to the deficiencies and additions to tax. Respondent mailed the respective notices of deficiency to petitioners on December 1, 1994. OPINION I. Unreported Income Burden of Proof Petitioners argue that the notices of deficiency in the instant case are arbitrary and excessive and request that we place upon respondent the burden of proof with respect to the issue of the income tax deficiency determined against petitionersPage: Previous 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 Next
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