- 45 - 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 establishPage: Previous 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 44 45 46 Next
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