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and (2) unreported income of $4,962.50 and $4,962.50,16 respec-
tively, for 1996 from his use of the January 31, 1996 check and
the July 31, 1996 check, which were payable to Mr. Thompson and
issued by Polaris with respect to Mr. Thompson’s investment.
Sale of Petitioner’s Arcade Games
With respect to petitioner’s receipt of petitioner’s sales
proceeds from the sale of the arcade games, petitioner claims on
brief that he gave those proceeds to his mother, Ms. Thompson.
Ms. Thompson’s 1996 return belies that claim. Ms. Thompson did
not report in Ms. Thompson’s 1996 return petitioner’s sales
proceeds from the sale of the arcade games.17 On the record
before us, we find that petitioner has failed to carry his burden
of showing that he does not have unreported income of $16,450 for
1996 from his receipt of petitioner’s sales proceeds from the
16Respondent acknowledges that the deemed admissions contain
a mathematical error in showing (1) the total of the January 31,
1995 check for $4,962.50 and the July 31, 1995 check for
$4,962.50 as $9,950 and (2) the total of the January 31, 1996
check for $4,962.50 and the July 31, 1996 check for $4,962.50 as
$9,950. The correct total of the two checks issued in 1995 is
$9,925, as is the correct total of the two checks issued in 1996.
Such correct totals shall be reflected in the parties’ computa-
tions under Rule 155.
17As indicated supra note 15, on Oct. 16, 2001, in the
presence of his mother, petitioner told respondent that his
mother was the actual recipient of certain income items that were
attributable to petitioner in the notice and that his mother
would amend her Federal income tax returns for 1995 and 1996 in
order to report such income items. As of the trial in this case,
petitioner had not proffered any amended return of Ms. Thompson
for 1996 reflecting that she reported for that year petitioner’s
sales proceeds from the sale of the arcade games.
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