-367- 94-5252, 94-2 USTC par. 50,479 (N.D. Ill. 1994); United States v. Administration Co., 74 AFTR 2d 94-5256, 94-2 USTC par. 50,480 (N.D. Ill. 1994). We conclude the evidence Kanter offered on this issue was insufficient to satisfy his burden of proof. Given the large amounts of the deposits in question, not to mention Kanter’s experience as a tax attorney, Kanter should have been prepared to offer additional records, such as loan documents, checks reflecting prior investments, checks reflecting principal or interest payments, or other accounting records in support of the proposition that the deposits in question were in fact loans or returns of capital. In the absence of such evidence, we sustain respondent’s determination that Kanter failed to report $1,303,207 of income for 1982. Issue IX. Whether Kanter Received Barter Income From Principal Services Accounting Corp. During 1988 and 1989 (STJ report at 133-135) Respondent determined in notices of deficiency issued to the Kanters for 1988 and 1989 that Kanter failed to report barter income he received from Principal Services Accounting Corp. (PSAC) during those years. These adjustments were resolved in petitioners’ favor, and the decisions entered by the Court at docket Nos. 26918-92 (taxable year 1988) and 25981-93 (taxable year 1989) on September 24, 2001, were not appealed and arePage: Previous 357 358 359 360 361 362 363 364 365 366 367 368 369 370 371 372 373 374 375 376 Next
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