Paul Arthur Zipp - Page 13

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          for computing income.  Estate of Mason v. Commissioner, 64 T.C.             
          651, 656-657 (1975), affd. 566 F.2d 2 (6th Cir. 1977).                      
          Petitioner bears the burden of proving that respondent's                    
          determinations, including unreported income, are incorrect.  Rule           
          142(a); Nicholas v. Commissioner, 70 T.C. 1057, 1064 (1978).                
               In the notice of deficiency, respondent determined that                
          petitioner failed to report $344,225 of gross receipts from his             
          business practice in 1990, $666,563 in 1991, and $231,212 in                
          1992.  For the 1990 and 1991 taxable years, petitioner has not              
          contested that the deposits into the accounts were income from              
          his medical practice.  Therefore, we find that petitioner failed            
          to report $344,225 of gross receipts from his business for 1990             
          and $666,563 for 1991.                                                      
               For the 1992 taxable year, respondent concedes (1) that                
          petitioner's income for 1992 does not include $177,726 deposited            
          in his SUB account, and (2) that the unreported income from                 
          petitioner's deposits in the FIB Roseburg account is $18,157 as             
          set forth in the bank deposits method rather than the $18,313               
          determined in the notice of deficiency.  On the basis of                    
          respondent's concessions and petitioner's failure to show that              
          any of the deposits were not income, we find petitioner failed to           
          report $53,330 of gross receipts in 1992 ($35,173 from the main             
          account and $18,157 from the FIB Roseburg account).                         







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