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light of Gallenberger’s regular practice of record destruction,
and the failure to respond to summonses issued by respondent.
See United States v. Administrative Enterprises, Inc., 46 F.3d
670 (7th Cir. 1995).
As to the funds Kanter received from Computer Placement
Services, one of the sources listed above, Mallin testified that
Kanter consulted with him and his company and Kanter was paid for
those services. Kanter's summary analysis relating to his
purported repayment of a loan from Computer Placement Services is
not supported by any underlying documentation.
Likewise, there is no convincing evidence that the funds
received by Kanter from the Administration Co. accounts were
loans. Again there is insufficient underlying documentation.
Accordingly, we hold that Kanter failed to prove that the
deposits in question were from nontaxable sources. Thus we
sustain respondent on this issue.
Issue 8. Whether Kanter Received Barter Income From Principal
Services in 1988 and 1989
FINDINGS OF FACT
In a notice of deficiency, respondent determined that Kanter
received and failed to report barter income from Principal
Services of $453,656 in 1988 and $581,530 in 1989. This
determination was made "in order to protect the revenue". There
was little or no evidence to support the determination at the
time the deficiency notice was issued. The determination was
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