- 5 -
made on the company's behalf. Petitioner testified that he
"didn't keep track" of the amounts received from Lighthouse and
did not have "any idea" how much cash he received from the
company. Nonetheless, he contends, it was less than the amounts
determined by respondent.
Although respondent made a determination in the deficiency
notice that petitioner had received and not reported Schedule C
gross receipts in the amounts previously noted, neither party
produced a Form 1099 or any other evidence to document the
precise amount of the payments from Lighthouse to petitioner.
Petitioner did not keep any record of the amount of cash he
received from Lighthouse, concedes that he did not file Federal
income tax returns containing estimates of the amounts received,
and was unable to make an estimate of these amounts at trial.
However, petitioner's own testimony and stipulations link him to
an income-generating activity and to the receipt of Schedule C
gross receipts that were not reported. Other than his
unsubstantiated assertion that the specific amounts are too
great, petitioner has produced no evidence that the Schedule C
gross receipts determined in the notice of deficiency were
erroneous. Respondent provided evidence that petitioner incurred
significant expenses during the years in issue and had no other
source of income beyond the W-2 income (totaling $6,493 for 1989,
$753 for 1990) and whatever amounts he received from Lighthouse.
In addition, respondent elicited testimony from petitioner that
Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011