Domer L. Ishler - Page 20




                                       - 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.                                                   





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