- 12 -
taxable income to him, and that in any event, if the large losses
and business expenses he incurred over the years are allowed, it
will be clear that net losses, not gains, were realized from
petitioner's numerous investment and business activities.
On the evidence in this case, we have found that under the
specific item method of proof petitioner is to be charged with
the following total gains and allowed the following total losses
from the sale of stock and commodities for each year:
Specific Items of
Year Gain and Loss
1984 $ 86,914
1985 15,385
1986 (5,313)
1987 (64,130)
1988 27,226
1989 83,165
Petitioner has not substantiated tax bases in the above sale
transactions in excess of those allowed by respondent.
Also, as we have found, petitioner is to be charged with
totals of $12,537 for 1984, $7,731 for 1985, $154 for 1987,
$15,071 for 1988, and $59,155 for 1989 in additional ordinary
income with regard to specific items of partnership
distributions, royalties, interest income, and fees.
For 1987 and 1988, also under the specific item method of
proof, respondent treats bank checks in the totals of $477,859
and $114,080, respectively (that petitioner received but which
were not deposited into petitioner’s bank accounts), as
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011