-37-
in amounts substantially in excess of the unreported taxable
income determined by respondent for those years, and petitioner
has not proved that he is entitled to any business expense
deductions from that unreported income.
With respect to 1993 and 1994 as well, petitioner's only
evidence concerning business expenses was the report and
testimony of Mr. Sager. The data and methodology underlying
Mr. Sager's estimates of petitioner's taxable income for 1993-94
are almost identical to the data and methodology underlying
Mr. Sager's estimates of petitioner's taxable income for 1989-92.
We therefore give Mr. Sager's estimates for 1993-94 little
weight, for the reasons set forth in our discussion of the
deficiencies for 1989-92.
We also note that Mr. Sager's testimony with respect to
1993-94 differed from his testimony with respect to 1989-92. On
the basis of his professional experience and the financial
reference books he consulted, Mr. Sager testified that
respondent's determinations of petitioner's taxable income for
1990-92 were unreasonable. By contrast, Mr. Sager did not opine
that respondent's determinations for 1993 and 1994 were
unreasonable.
Finally, although the parties have stipulated that
petitioner had some gross receipts for 1993 and 1994, they have
not stipulated petitioner's total gross receipts for either of
those years. Petitioner's actual gross receipts and actual
taxable income for 1993 and 1994 may have been greater than the
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