- 6 - 1989. Respondent's additional gross receipts computation was based, in part, on documents (i.e., customer contracts and illegible checks), which were not probative evidence that V&V received income. As a result, respondent's computation overstated V&V's gross receipts by $30,561 for 1988 and $12,121 for 1989. Accordingly, we hold that Messrs. Vazzana and Valenza underreported V&V's gross receipts by $121,289 for 1988 and $101,029 for 1989. II. V&V Expenses Petitioners contend that V&V made substantial cash expenditures to subcontractors for which they did not claim deductions. Specifically, they contend that V&V paid J. B. Johnson, a handyman, $40,000 in 1988 and $36,000 in 1989. Petitioners have failed, however, to provide any documentation to establish that V&V paid Mr. Johnson such funds. Mr. Johnson's testimony was contradictory and unpersuasive. He first stated that he had received the income and reported it on his tax returns. He later stated that he did not report the income, had no records of receiving such income, and may not have received the amounts petitioners contend V&V paid him. Petitioners contend that V&V paid Frank Schmitt, a carpenter, $9,320 in 1988 and $11,960 in 1989. Mr. Schmitt testified that he received these amounts and reported them as income on his Federal income tax returns. Petitioners providedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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