- 20 - L. The Notices of Deficiency Respondent began the audit of these cases before October 1990 and issued notices of deficiency to petitioner and TCM on May 12, 1999. OPINION A. Unreported Income 1. Contentions of the Parties Respondent contends that petitioner had unreported income of $308,723.366 in 1987 and $1,421,217.977 in 1988, and that TCM had unreported income of $307,695.618 in 1987.9 Respondent contends that TCM was taxable on the commissions NSA paid to Camaro in 1987 and on the 1987 checks payable to TCM but deposited in petitioner’s personal checking account or the Double D account or cashed without being deposited. Respondent also contends that 6 Respondent determined that petitioner had unreported income of $310,314.00 for 1987 but now contends that petitioner had unreported income of $308,723.36. 7 Respondent determined that petitioner had unreported income of $1,404,026 for 1988 but now contends that petitioner had unreported income of $1,421,217.97. Respondent bears the burden of proving the increased deficiency. Rule 142(a)(1). 8 Respondent determined that TCM had unreported gross receipts of $309,286 for 1987 but now contends that TCM had unreported gross receipts of $307,695.61. 9 Respondent contends that TCM had unreported income of $307,696 and petitioner had unreported income of $308,723 for 1987. The difference ($1,027) in those amounts is attributable to adjustments made by respondent affecting only the return of either petitioner or TCM.Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
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