- 22 -                                         
          Commissioner, 31 T.C. 1269 (1959), affd. in part and revd. in               
          part on another issue 283 F.2d 871 (6th Cir. 1960); Bolton v.               
          Commissioner, T.C. Memo. 1975-373.                                          
               Petitioner failed to produce records establishing his gross            
          receipts from his yacht charter business for 1994, 1995, and                
          1996.  Using third-party records, respondent determined that                
          petitioner’s gross receipts were $144,217, $415,018, and $364,247           
          in 1994, 1995, and 1996, respectively, resulting in a                       
          determination of unreported gross receipts of $68,350, $190,615,            
          and $34,544 in those years.                                                 
               As outlined in our findings, with respect to 1994,                     
          petitioner has admitted depositing charter receipts of $116,09514           
          and other amounts which bring total deposits to $152,342, as                
          compared to respondent’s determination that his gross receipts              
          were $144,217.  With respect to 1995, petitioner has admitted               
          depositing charter receipts of $399,23915 and other amounts which           
          bring total deposits to $404,972, as compared to respondent’s               
          determination that his gross receipts were $415,018.  With                  
          respect to 1996, petitioner has admitted depositing charter                 
          receipts of $318,471 and other amounts, which bring total                   
               14 This figure exceeds petitioner’s reported gross receipts            
          for 1994 by $41,202.                                                        
               15 This figure exceeds petitioner’s reported gross receipts            
          for 1995 by $182,812.                                                       
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