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happened to the $132,092.20 that petitioner withdrew from peti-
tioner’s American Savings Bank CD on April 6, 1998. On the
record before us, we find that petitioner has failed to carry his
burden of establishing that he timely transferred, or rolled
over, the retirement plan distributions in question into an
eligible retirement plan. On that record, we sustain respon-
dent’s determination to include those distributions in peti-
tioner’s gross income for the year at issue.
We turn next to petitioner’s claim that he is entitled for
1998 to a deduction for a claimed loss with respect to his
radiology practice. Although we are satisfied from the record
that petitioner’s radiology practice was closed on May 25, 1997,
no reliable evidence in the record explains why that practice was
closed. In fact, the record does not even establish whether
petitioner carried on his radiology practice in corporate form,
in partnership form with one or more other physicians, or as a
sole proprietor. In addition, much of the documentation on which
petitioner relies to support his claimed loss for 1998 relates to
years other than 1998.5 On the record before us, we find that
petitioner has failed to carry his burden of establishing that he
5One of the documents upon which petitioner relies to sup-
port his claimed loss for the year at issue is a self-serving,
uncorroborated document prepared by petitioner, in which he
listed various items that he contends were related to his radiol-
ogy practice and various dollar amounts with respect to such
items.
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