- 34 - return. He claims the IRS characterized the items as corporate expenses. The record contains two documents from the audit of petitioner’s 1987 return, a statement of income tax examination changes and a partially redacted copy of a letter from the revenue agent. Although it is clear that certain deductions were removed from petitioner’s individual return pursuant to the audit, neither document refers to the crop hail insurance business, Taxman, or WFIC. We find no relevance in the audit documents regarding the sale of the crop hail insurance business. We conclude that petitioner has not met his burden of proving that the crop hail insurance business was transferred to Taxman and WFIC. Consequently, any sale proceeds or commission income earned by Jondahl Insurance while petitioner owned the insurance business was properly taxable to petitioner, not WFIC or Taxman. Three checks from Mr. Ihry to Jondahl Insurance are in the record evidencing the payment of the purchase price, dated May 9, 1990, November 2, 1990, and November 19, 1990, for $1,000, $3,962, and $10,000, respectively. The purchase agreement between petitioner and Mr. Ihry provided that petitioner would receive commissions from Farmer’s Mutual earned in 1990 and 1991, and the amount Mr. Ihry owed would be reduced by the amount of the commissions. The parties stipulated that Jondahl Insurance received $10,038 from Farmer’s Insurance in 1990, representing aPage: Previous 24 25 26 27 28 29 30 31 32 33 34 35 36 37 38 39 40 41 42 43 Next
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