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Year Amount Payee
1989 $500 Cash
1989 500 Cash
1989 312 DS.BA
1990 1,000 Cash
1990 3,450 Sweda Heating & Cooling
1990 1,316 R. C. Drywall
Total 17,078
1B. L. Holtzhauer signed one check in the amount of $60, payable to Universal
Disposal in 1992.
Petitioner was in the process of remodeling and expanding
his personal residence in 1989.
Petitioner made a $5,000 deposit into the Second National
106 account in 1988. The source of the $5,000 deposit was a bank
check payable to petitioner drawn from one of the Dollar Savings
and Trust accounts.
Petitioner filed Form 1040, U.S. Individual Income Tax
Return, for the years 1975 through 1979. Petitioner did not file
a Federal income tax return for 1980, and he has not filed a
Federal income tax return for any year since 1980.
OPINION
I. Unreported Income
Petitioner failed to file Federal income tax returns for the
years 1988, 1989, 1990, 1991, and 1992. Respondent determined
that petitioner was engaged in the business activity of
performing veterinary services and selling livestock during those
years. Respondent computed petitioner’s business gross receipts
based on deposits made to bank accounts which petitioner
controlled during those years, taking into account transfers and
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