Estate of Burton W. Kanter, Deceased, Joshua S. Kanter, Executor, and Naomi R. Kanter, et al. - Page 304

                                                -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 are                                 







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