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Petitioner contends that the sale was not reported on any
returns because it was an installment sale that was not
completely paid off until 1991. We disagree with petitioner’s
characterization and treatment of the transaction. Petitioner
produced no evidence that the sale of any Sipsey Harbor lot was
structured as an installment sale. Petitioner failed to
introduce any type of mortgage note between himself and Ann
Burdick or Tarrie Hyche evidencing payments for the Sipsey Harbor
lots. Petitioner failed to elaborate on the sale of the six lots
in 1989 and 1990. Petitioner also failed to explain why no
portion of any proceeds of the sales of those six lots or any
other lots were reported on any of his returns. In short,
petitioner offered no explanation for his complete failure to
report any Sipsey Harbor transaction. Accordingly, we sustain
respondent’s determination with regard to petitioner’s capital
gain from the sale of Sipsey Harbor.
Trucks
Petitioner sold several trucks during the years in issue.
Respondent verified the number of sales of petitioner’s trucks by
contacting the parties who purchased the trucks. Respondent
determined that petitioner sold 13 trucks in 1989, but
petitioner’s 1989 return reflects the sale of only 9 trucks.
Respondent determined that petitioner sold two trucks in 1990,
but petitioner’s 1990 return did not reflect any truck sales.
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