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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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