- 131 - 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 312,437Page: Previous 121 122 123 124 125 126 127 128 129 130 131 132 133 134 135 136 137 138 139 140 Next
Last modified: May 25, 2011