Rodney W. and Lynnell R. Frazier - Page 3




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                                                       Amount of                      
          Year           Source of Income               Income Reported                
          1993           Schedule C income              $715                           
                         Interest income                     20                        
          1994           Wages                               29,097                    
                         Dividend income                     134                       
                         Schedule C income                   670                       
          1995           Wages                               38,433                    
                         Interest                            29                        
                         Dividends                           141                       
                         Schedule C loss                     (3,534)                   

               In 1993, petitioner husband purchased a house, which he sold            
          in 1994, resulting in a capital gain of $2,340.                              
               Respondent determined that for taxable year 1993 petitioner             
          husband had unreported income in the amount of $28,933, and that             
          for taxable years 1994 and 1995, petitioners had unreported                  
          income of $31,607, and $17,828, respectively.  Respondent also               
          determined that petitioners had unreported capital gain of $2,340            
          in taxable year 1994.                                                        
               In their petition, petitioners alleged that they did not                
          engage in any taxable activities during the years at issue.                  
                                      Discussion                                       
               Generally, the Commissioner’s determinations are presumed               
          correct, and the taxpayer bears the burden of proving that those             
          determinations are erroneous.  Rule 142(a); Welch v. Helvering,              
          290 U.S. 111, 115 (1933).  In certain circumstances involving                
          unreported income, respondent must make some minimal evidentiary             





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