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is presumed to be correct, and petitioner bears the burden of
proving otherwise. Rule 142(a).
Petitioner argues that there is no unreported income.
Petitioner, however, offers conclusions without argument or
evidence to support them. Additionally, on brief, petitioner
concedes that he underreported his medical practice income by
$17,170.91 in 1985 and $44,401.56 in 1986. Petitioner's
testimony was at times questionable, vague, conclusory, not
credible, and was unsupported by the evidence in the record.
Under these circumstances, we are not required to, and do not,
rely on petitioner's testimony to sustain his burden of
establishing error in respondent's determinations. See Lerch v.
Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989), affg. T.C.
Memo. 1987-295; Tokarski v. Commissioner, supra at 77.
A. Medical Practice Income
Respondent determined that petitioner had unreported income
in 1985, 1986, and 1987 from petitioner's medical practice as
follows:
Year Total Income Reported Income Adjustment1 Unreported Income
1985 $173,096.33 $148,947.76 ($1,607.66) $22,540.91
1986 204,540.30 151,375.44 26,627.30 79,792.16
1987 214,217.13 157,126.69 (26,627.30) 30,463.14
1 Respondent made the above listed adjustments to reconcile the
deposits to the year of receipt.
Petitioner has failed to show that respondent's determination is
incorrect; therefore, we sustain respondent's determination.
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