James O. Jondahl - Page 31

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         not met his burden of showing that petitioner earned the real                
         estate commissions.7                                                         
              Petitioner argues that expenses associated with the real                
         estate commission he earned should be taken into account.  The               
         burden of proving entitlement to deductions is on petitioner.                
         See INDOPCO, Inc. v. Commissioner, 503 U.S. 79, 84 (1992).                   
         Because petitioner did not present any evidence that he paid any             
         expenses or is entitled to any deductions against the real estate            
         income, we conclude that the full amount of the 1992 commission,             
         $1,566, is income to petitioner.                                             
         V.   Other Adjustments                                                       
              A.   Sale of and Commissions From Crop Hail Insurance                   
                   Business                                                           
              Petitioner sold crop hail insurance as a sole proprietor                
         beginning in 1977.  He asserts that in 1986, his crop hail                   
         insurance business was transferred to Taxman, along with his tax             
         preparation and bookkeeping businesses.  He claims that in 1989,             
         Taxman transferred the crop hail insurance business to WFIC                  
         because it was confusing for customers to receive crop hail                  
         insurance bills from a company called “Taxman”.  On May 9, 1990,             
         petitioner entered into a purchase contract with Mr. Ihry to sell            


               7Respondent did not raise the potential application of sec.            
          482 to petitioner’s arrangement with WFIC.  See, e.g., Haag v.              
          Commissioner, 88 T.C. 604, 614 (1987), affd. without published              
          opinion 855 F.2d 855 (8th Cir. 1988).  Therefore, we do not                 
          address it.                                                                 




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