- 46 -
corporate tax return. Therefore, we agree with respondent that
petitioner must report the $13,674.35 as compensation received in
1992.
4. Unreported Income in 1993
In 1993, Taxman paid $310 to repair a 1991 Ford Probe owned
by Mary. Petitioner argues that the $310 was an expense of
Taxman because he used the car on business trips. Specifically,
petitioner testified that he “thinks” he used Mary’s car “a
couple of times for business trips.” Petitioner offered no
evidence beyond his testimony on the business trips for which he
used Mary’s car. Given the uncertainty with which he testified
and his lack of proper record keeping, petitioner has not met his
burden of proving that the $310 for the car repair was not
compensation to him in 1993.
In 1993, WFIC, doing business as Epic Real Estate, brokered
a real estate transaction for petitioner’s sister, Ms.
Schoeppach. As part of the transaction, WFIC issued a check for
$7,000 to Ms. Schoeppach. Eight days later, Ms. Schoeppach paid
Epic Real Estate $7,000 as a downpayment. Respondent determined
in the notice of deficiency that the $7,000 payment by WFIC to
Ms. Schoeppach was income to petitioner. Petitioner argues that
after the transaction was completed, he canceled Ms. Schoeppach’s
$7,000 debt to WFIC because Epic Real Estate received a $9,000
commission which WFIC reported on its 1993 corporate return.
Page: Previous 35 36 37 38 39 40 41 42 43 44 45 46 47 48 49 50 51 52 53 54 NextLast modified: May 25, 2011