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               Petitioner argues that if the income items in appendixes F             
          through J are attributed to him, then respondent has failed to              
          subtract expenses or deductions from petitioner’s gross receipts            
          for each year in issue.  However, petitioner did not provide any            
          evidence regarding allowable expenses or deductions, and neither            
          petitioner nor his wife testified.                                          
               Even in criminal tax evasion cases, where the Government               
          bears the greater burden of proof beyond a reasonable doubt, it             
          is well settled “that evidence of unexplained receipts shifts to            
          the taxpayer the burden of coming forward with evidence as to the           
          amount of offsetting expenses, if any.”  Siravo v. United States,           
          377 F.2d 469, 473 (1st Cir. 1967); see also Franklin v.                     
          Commissioner, T.C. Memo. 1993-184.  Where the taxpayer has failed           
          to file a return, or his return shows no receipts from a                    
          particular activity, then the assumption that he, more readily              
          than respondent, has access to evidence of deductions or other              
          offsetting amounts makes the nonexistence of such amounts a fair            
          presumption, at least as an initial matter and absent a                     
          satisfactory explanation of such nonexistence or the production             
          of some probative evidence.  See Franklin v. Commissioner, supra.           
               We hold that petitioner had unreported taxable income of               
          $47,750 in 1988, $88,404 in 1989, $77,149 in 1990, $18,258 in               
          1991, and $20,083 in 1992.  See appendixes F through J.                     
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