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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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