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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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