- 26 -
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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