Caralan Trust, et al. - Page 38




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          account of unreimbursed expenses related to Congo Trust.                    
          Respondent concedes that adjustment on the ground that it was a             
          mistake (it should have been a positive adjustment).  A third               
          adjustment is a positive adjustment in the amount of $65,951 on             
          account of trust “gross receipts”.  From respondent’s trial                 
          memorandum, we learn that such third adjustment combines two                
          adjustments, the first being an adjustment of $63,481, on account           
          of the income distribution received by the C E Shirley Trust, and           
          the second being an adjustment of $2,470 on account of gross                
          receipts from business omitted from gross income by the                     
          C. Shirleys.  Respondent concedes the $63,481 adjustment on the             
          ground that it duplicates, in part, the adjustment made to the              
          J. Shirleys’ gross income on account of Alexion Trust’s gross               
          receipts.  The $2,470 adjustment constitutes a new matter, on               
          which respondent bears the burden of proof.  See Rule 142(a).  We           
          accept respondent’s concessions and agree he bears the burden of            
          proof with respect to the $2,470 item.                                      
               Given respondent’s concessions, we are left to consider                
          three positive adjustments:  interest income of $25, unreported             
          deposits of $33,980, and unreported business gross receipts of              
          $2,470.                                                                     
                    2.  Discussion                                                    
               In the C. Shirleys’ notice of deficiency, respondent’s                 
          ground for the interest adjustment is:  “All interest income is             






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