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evidence. Even if we had, it would be unconvincing because the
note does not state to whom petitioner is to repay the money or
when the loan was made, and petitioner signed the note more than
4 years after his father allegedly lent him the money.
3. Petitioner’s Business Gross Receipts
Petitioner contends that respondent’s use of the bank
deposits method overstated his income for 1994 and 1995. He
contends that he correctly reported gross receipts from his tax
preparation business of $38,658 on his 1995 return. He contends
that Joseph Goggans (Goggans), doing business as Rapid Refund,
issued a Form 1099-MISC, Miscellaneous Income, showing Goggans
paid petitioner nonemployee compensation of $38,658.19 in 1995.
At trial, petitioner offered into evidence Exhibit 16-P, the
purported Form 1099-MISC from Goggans. We did not admit Exhibit
16-P into evidence because petitioner had not exchanged it before
trial as required by our Standing Pretrial Order. We disagree
that petitioner correctly reported his gross receipts for 1995.
Although petitioner testified that he received about 10 checks
totaling about $38,000 in 1995 from Goggans, he did not produce
copies of any of those checks or show which deposits to his
account in 1995 were from Goggans.
Petitioner contends that respondent overstated his gross
receipts for December 1995 by using his bank records for
September to November 1995. We disagree. Petitioner has not
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