- 27 - In his farming business, petitioner received gross receipts from the sale of milk, livestock, corn, and shelled corn. The evidence, including copies of canceled checks, settlement sheets, receipts, invoices, and the testimony from petitioner’s criminal proceeding, clearly and convincingly establishes that petitioner failed to report gross income from his farming business. We adjust respondent’s calculation of petitioner’s total unreported farming income with respect to the bartering income he received from Fred Hoover. Respondent determined that petitioner received bartering income of $5,569.32 in 1990, $7,598.75 in 1991, and $4,743.32 in 1992. The records of Fred Hoover reflect that in 1991 he issued a $5,569 check to petitioner for the excess of goods and services attributable to 1990. Because petitioner received the check for $5,569 in 1991, petitioner failed to report this income in 1991, not in 1990 as respondent argues. See secs. 446(c), 451(a). These records also show that in 1992 Fred Hoover issued a $7,598.75 check to petitioner for the excess of goods and services attributable to 1991. Petitioner failed to report this $7,598.75 in 1992, the year in which he received this payment. In 1993, Fred Hoover issued a $4,743.32 check to petitioner for the excess of goods and services attributable to 1992. Because petitioner received the check relating to the 1992 bartering income in the 1993 taxable year, we find that the bartering income of $4,743.32 is notPage: Previous 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 34 35 36 Next
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