- 14 - that respondent apportioned one-half of these wages to each petitioner to reflect the community property law of Texas and that petitioners have made no objection to this apportionment. As to the newspaper income, petitioners’ sole argument is that respondent has neither connected them to the receipt of income from the newspaper nor established the amount of any such income. Petitioners assert primarily that respondent’s determination of this unreported income was not the product of a thorough and complete examination but rested on a naked assessment. In this regard, petitioners observe, respondent’s income calculation stemmed solely from one edition of the newspaper, and respondent never attempted to verify his income recalculation by using another method such as the net worth method. Petitioners assert secondly that respondent never investigated whether the calculated amount of advertising income should have been reduced by virtue of, for example, the four consecutive issue discount or a complimentary (free) placement. On the basis of the facts herein, we are satisfied with respondent’s reconstruction of petitioners’ unreported income from the newspaper. Mr. Burnett was the sole proprietor and publisher of the newspaper, which both on its face (the listing of subscription, advertising, and classified rates) and on the basis of history (the 1992 tax return), was easily seen to be an income-producing activity. Because petitioners did not filePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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