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Respondent has also proven that petitioner is liable for self-
employment taxes of $5,166 for 1986. Respondent has proven an
underpayment for 1986 by clear and convincing evidence.
3. Underpayment for 1987
For 1987, petitioner has specifically conceded the following
amounts as income; see appendix C:
Income item Amount
Schedule C miscellaneous income $24,000
Gains from property sales 946,649
Schedule C interest income 9,084
Total 979,733
In addition, petitioner did not address on brief the following
items of income:
Income item Amount
Gain from sale of Silver Lake $24,577
Interest income 5,488
Total 30,065
Petitioner has conceded those items. Respondent has produced
affirmative evidence for each of the items conceded, and he has
proven those items of income by clear and convincing evidence.
Thus, respondent has proven by clear and convincing evidence that
petitioner received income of $1,009,798 ($979,733 + $30,065) in
1987.
Respondent allowed the following deductions for 1987:
Type of deduction Amount
Schedule C expenses $265,076
Itemized deductions 43,561
Exemptions 3,800
Total 312,437
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