Leo M. Ryan, et al. - Page 26

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          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 petitioners           




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