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v. Commissioner, 877 F.2d 624, 631-632 (7th Cir. 1989), affg.
T.C. Memo. 1987-295; Geiger v. Commissioner, 440 F.2d 688, 689-
690 (9th Cir. 1971), affg. per curiam T.C. Memo. 1969-159;
Tokarski v. Commissioner, 87 T.C. 74, 77 (1986). There is no
credible evidence (1) regarding the amounts of alleged loans
received during the years in issue, (2) that petitioner ever
deposited the alleged loans into the minimart’s bank accounts, or
(3) that the amounts of gross receipts listed on the 1995, 1996,
1997, and 1998 returns included the alleged loans.
We treat the gross receipts listed on petitioners’ returns
as admissions that petitioners had gross receipts of at least
those amounts. See Lare v. Commissioner, 62 T.C. 739, 750
(1974), affd. without published opinion 521 F.2d 1399 (3d Cir.
1975). The evidence presented at trial is unpersuasive and
insufficient to support lower gross receipts figures.
Additionally, petitioners reported $6,364 more in gross receipts
for 1995 to the State Board of Equalization than to the Internal
Revenue Service. Respondent determined that petitioners’ gross
receipts should be increased by this amount for 1995.
Accordingly, we sustain respondent’s determination regarding
petitioners’ gross receipts for 1995.
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