Eddie Stricklin - Page 5

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          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             




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