- 32 - the crop hail insurance business for $25,000. Respondent argues that the $25,000 is income to petitioner in 1990. Petitioner has the burden of proving that the sale proceeds were not income to him. Petitioner maintains that WFIC owned the crop hail insurance business when it was sold. Petitioner did not present any documentation of the purported transfers of the business to Taxman and to WFIC. In the 1987 deposition, petitioner admitted that the transfer to Taxman was not documented. The 1990 purchase agreement was between Mr. Ihry and Jondahl Insurance, not WFIC. Likewise, the checks paid for the purchase of the business by Mr. Ihry were made out to Jondahl Insurance, although petitioner deposited the checks into WFIC’s bank account. Jondahl Insurance was a party to agency agreements with Farmer’s Mutual and Old Republic Insurance Co. in 1986 and 1989, after its alleged transfer. Neither Taxman nor WFIC is mentioned on either contract. Farmer’s Mutual listed “Jondahl Insurance Agency” on its policy registers for 1990 and 1991. Petitioner has not shown any evidence to support his claim that his insurance customers received bills from Taxman or that any customers were confused as to the ownership of the business. In addition, petitioner did not report capital gain from the sale of the insurance business on WFIC’s 1990 or 1991 corporate return.Page: Previous 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 Next
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