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In this case, petitioner disputes respondent’s determination
of unreported income for 1991 and 1992, claiming that there is no
reliable evidence that she earned taxable income in those years.
To the contrary, she maintains, after 1990 she abandoned her
business activities and moved in with family members who
supported her.
Evidence linking petitioner to taxable income for 1991 and
1992 is no more than tenuous. Revenue Agent Schnorbus, who
examined petitioner’s tax liability for the years in issue,
testified that the majority of the parties he interviewed told
him that they did not have dealings with petitioner in 1991 or
1992. Agent Schnorbus was not aware of any bank accounts which
reflected that petitioner earned income or had a business in 1991
or 1992.
Agent Schnorbus indicated that he believed that two of
petitioner’s associates, Jeffrey F. and Richard S., had told him
that they had engaged in business activities with petitioner
during 1991 and 1992. Agent Schnorbus conceded, however, that
neither had provided canceled checks nor other documents showing
that there were any such dealings in those 2 years. Moreover,
although respondent introduced notes of an interview that Agent
Schnorbus had conducted with Mr. F., those notes make no
reference to petitioner’s receipt of income for 1991 or 1992.
Finally, Agent Schnorbus stated that although he had made notes
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