Wesley W. and Patsie Burnett - Page 14




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          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 file                






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