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Type of deduction Amount
Schedule C expenses $225,301
Itemized deductions 22,567
Exemptions 2,080
Total 249,948
Respondent has proven by clear and convincing evidence that
petitioner received taxable income of $305,94083 in 1985.
Respondent has also proven that petitioner is liable for self-
employment taxes of $4,673 for 1985. Respondent has proven an
underpayment for 1985 by clear and convincing evidence.
2. Underpayment for 1986
For 1986, petitioner has specifically conceded the following
amounts as income; see appendix C:
Income item Amount
Schedule C miscellaneous income $27,019
Gains from property sales 154,924
Schedule C interest income 10,614
Schedule C commission income 32,357
Schedule C unidentified deposit 24,186
Total 249,100
In addition, petitioner did not address on brief the following
items of income:
Income item Amount
Gain from sale of Tract A in
Susan’s Lakefront Estate $21,097
Installment gain from Silver Lake sale 12,288
Interest from Silver Lake 5,805
Deposit on May 6, 1986 300
Deposit on Oct. 10, 1986 300
Total 39,790
83Total income proven of $555,888 less allowable deductions
of $249,948 equals $305,940 in taxable income.
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