- 29 - JAC Ranch. Although petitioner did provide funding to Mrs. Corrigan for the operation of the activity, there is no showing that the character of these advances was debt or equity. Even if the advances constituted an equity interest, that would not necessarily entitle petitioner to share in profits and losses. Petitioner has alleged that there was a written agreement between him and Mrs. Corrigan regarding the sharing of profits and losses, etc. No such agreement was produced, and no corroborating evidence was provided in support of petitioner’s self-serving allegations. In view of the foregoing, we hold that petitioner has not shown that he is entitled to claim losses from the horse breeding activity. VII. Unreported Income Respondent determined that petitioner failed to report various items of income, including dividends, interest, State income tax refunds, and royalties during the years in issue. With the exception of a $1,902 adjustment that respondent now concedes was in error, petitioner has failed to present any evidence to show that respondent’s determination was in error. The net amounts of unreported income for 1987, 1989, 1990, and 1991 are $44, $5,587, $15, and $26, respectively. For 1988, respondent determined that petitioner overstated the various items of income by a net amount of $539.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 Next
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