-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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