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Respondent has proven by clear and convincing evidence that
petitioner received taxable income of $697,36185 in 1987.
Respondent has proven by clear and convincing evidence that
petitioner is liable for self-employment tax of $5,387.
Petitioner reported taxable income of $37,879, a tax of $7,515 on
that amount, and self-employment tax of $5,387. Respondent has
proven an underpayment for 1987 by clear and convincing evidence.
4. Underpayment for 1988
For 1988, petitioner has specifically conceded the following
amounts as income; see appendix C:
Income item Amount
Schedule C miscellaneous income $12,000
Gains from property sales 167,120
Unidentified deposits 4,400
Total 183,520
In addition, petitioner did not dispute on brief the following
items of income:
Income item Amount
Gain from sale of Lots 6-30 in
Susan’s Lakefront Estate $77,298
Gain from sale of Mefford property 55,164
Rents received from Island Living, Inc. 12,000
Total 144,462
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.
85Total income proven of $1,009,798 less allowable
deductions of $312,437 equals $697,361 in taxable income.
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