James D. and Rita K. Snyder - Page 26




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          939 F.2d 874, 879 (9th Cir. 1991).  Because the record contains             
          no evidence upon which we could base such an estimate, we                   
          conclude that petitioners have failed to prove that they are                
          entitled to claim any deductions under section 162(a) or any                
          other section or any costs of goods sold.                                   
               C.  Conclusion                                                         
               The income adjustment on account of Complete Connections               
          Trust for 1992 is $194,205, while gross receipts reported by                
          Complete Connections Trust for that year are only $183,482 (no              
          miscellaneous items of income are reported).  There is no                   
          explanation for that difference, and, therefore, we cannot                  
          sustain an income adjustment for 1992 on account of Complete                
          Connections Trust in an amount greater than $183,482.  For J&R              
          Trust for all years, and for Complete Connections Trust for 1993            
          through 1995, we sustain income adjustments in the amounts                  
          determined by respondent, except as follows.  For all years,                
          income attributed from the trusts to petitioners must be reduced            
          to reflect income distributions from J&R Trust to petitioners               
          reported on the 1992 through 1995 Forms 1040 and salary payments            
          and any other amounts so reported.  The parties shall take such             
          adjustments into account in making the Rule 155 computation here            
          required.                                                                   
          III.  Penalties                                                             
               A.  Section 6662(a)                                                    






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