- 31 - 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.Page: Previous 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 Next
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