Robert E. Corrigan - Page 29

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          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.                                    






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