- 27 - respondent’s determination, other than their own biased testimony. Accordingly, we sustain respondent’s determination. See Rule 142(a). Income From Pay Telephone Receipts Petitioners argue that respondent’s estimate of pay telephone receipts is unreliable and arbitrary. Petitioners claim that respondent should have subpoenaed the telephone records to determine the actual amount of money received. However, petitioners have failed to produce any telephone records that would refute respondent’s estimate. Accordingly, petitioners have not satisfied their burden of proving respondent’s determination wrong. See id. On the basis of our review of the record, we find that petitioners failed to meet their burden of proof as to each category of income that respondent’s determination comprises. Accordingly, we sustain respondent’s determination that Crabtree Investments underreported its gross income in each of the taxable years in issue. Deficiencies The second issue for decision is whether one-half of the unreported income of Crabtree Investments for each of the years in issue is a constructive dividend to each ofPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
Last modified: May 25, 2011