- 385 - 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 wasPage: Previous 375 376 377 378 379 380 381 382 383 384 385 386 387 388 389 390 391 392 393 394 Next
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