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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 a
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