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petitioner contends that the $28,560 payment comprised a
$960 payment and a $27,600 payment. Subsequently, in his
answering brief, petitioner contends that the $28,560
payment comprised a $26,700 payment, consistent with the
amount listed on the copy of the check stub introduced at
trial, and a $1,860 payment.
Furthermore, petitioner maintained a multifaceted
business relationship with Dr. Strom. Petitioner's returns
report wages from Dr. Strom's professional corporation
totaling $24,252 in 1989 and $18,409 in 1990. Dr. Strom
was also a client of petitioner's Schedule C business and,
in that connection, petitioner claims to have made a direct
payment to Dr. Strom of $930 because Dr. Strom "didn't feel
the investments performed as well as expected". Dr. Strom
was also an investor in one or more of the partnerships
petitioner promoted. In view of these relationships,
petitioners's testimony is too vague to substantiate the
offset or deductions he claimed for 1990 in the aggregate
amount of $21,679.75. In this connection, we also note the
fact that petitioner did not produce to respondent the
retainer agreement between himself and Dr. Strom or seek
to introduce the agreement at trial.
As a result of the inconsistent and insufficient
evidence he presented, petitioner has failed to establish
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