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Dr. Strom as gross receipts on Schedule C of his 1990
return. As mentioned above, petitioner produced a
handwritten list of the names of his clients and the
amounts that petitioner allegedly received from these
clients in 1990. According to the handwritten list,
petitioner included $28,560 from Dr. Strom in the
calculation of his gross receipts for that year.
We find that the evidence petitioner adduced is
insufficient to establish that amounts reimbursed by
Dr. Strom were included in the computation of petitioner's
gross receipts for 1990. According to the handwritten
list, petitioner's gross receipts for 1990, $185,966, does
not equal the gross receipts reported on Schedule C of
petitioner's 1990 return, $175,790. Petitioner has failed
to adequately explain this inconsistency. Furthermore,
the handwritten list of fees introduced at trial is not
supported by any other evidence, such as books, receipts,
or other documentation.
In addition, petitioner's testimony regarding the fees
of $28,560 received from Dr. Strom in 1990 and allegedly
included in his gross receipts for that year is confusing.
At trial, petitioner testified that Dr. Strom's fees of
$28,560 consisted of a $26,200 payment and "other checks
representing $2,300". In his opening brief, however,
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