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including (but not limited to) the following items: (1)
Compensation for services * * * (4) Interest; (5) Rents; * * *
(11) Pensions; * * * [and] (13) Distributive share of partnership
gross income”.
At trial petitioner did not dispute any of the unreported
gross income amounts determined by respondent in the 1996 notice
and the amendment to answer. In fact, in his Reply To Amendment
To Answer and at trial, in response to questions concerning items
of income, petitioner admitted he received: The nonemployee
compensation in the amount of $690 from Nader Afrooz, the rental
income from Coldwell Banker in the amount of $1,225, money from
First Nationwide Bank, and the distribution of profits from
Quality. Petitioner did not raise any argument at trial as to
the assertion of respondent that petitioner had $108 interest
income from Mather Federal Credit Union and $11 of interest
income from Countrywide. We deem these amounts conceded.
At trial, petitioner claimed the $1,225 of rental income
belonged to another individual. However, petitioner admitted he
“rented the house” and someone paid him rent. Petitioner offered
no corroborative testimony or documentary evidence that the
rental income in fact belonged to someone else. We are not
required to accept petitioner’s generalized statements and
decline to do so here without further supporting evidence.
Geiger v. Commissioner, 440 F.2d 688 (9th Cir. 1971), affg. T.C.
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