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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 of
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