- 3 - 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 evidentiaryPage: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011