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During trial, while asserting the same claims, petitioner
successfully showed errors in respondent’s schedules summarizing
the 22 receipt books. Those records, as explained in
petitioner’s testimony, also reflected nontaxable reimbursements
and deductible expenses. Petitioner did not present any
additional evidence of deductions. In his opening brief,
respondent corrected the errors and made appropriate concessions
based on the receipt books received in evidence. Petitioner has
not made any further attempt to show errors in respondent’s
revised computations. Instead, he pursues a hodgepodge of
nonmeritorious contentions.
Respondent’s Position
In respondent’s brief, respondent tabulated the various
receipt books and derived new totals of gross receipts for
petitioner for 1982 and 1983. Respondent’s revised totals are
$339,866.54 for 1982 and $130,710 for 1983. In recomputing the
gross receipts, respondent omitted items identified in the
receipt books as reimbursement of expenses, a loan from
petitioner’s father, and receipts marked “VOID”. Respondent
concedes that petitioner paid wages of $10,901.53 in 1982 and
$24,216 in 1983. Respondent also concedes that petitioner paid
filing fees of $210 in 1982 and $175 in 1983, paid for services
rendered by Justo in the amount of $1,907.50 in 1982, and paid
bail bond expenses of $500 in 1982. Respondent also concedes
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