Michael W. Rehtorik, et al. - Page 12

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                    Year                      Unreported Income                       
                    1984                           $287,081                           
                    1985                           275,446                            
                    1987                           255,290                            

               At trial and in her briefs, respondent has made revisions to           
          the above determination of unreported income, as reflected below:           

                                                Respondent's Revised                  
                                           Determination of Petitioner’s              
                    Year                   Unreported Income                          
                    1984                              $263,054                        
                    1985                              192,399                         
                    1987                              244,449                         
                                           Total      $699,902                        

               For 1984, 1985, and 1987, respondent did not allow as                  
          business expenses or otherwise give petitioner credit against any           
          of the bank deposits that respondent treated as unreported                  
          taxable income to petitioner, any of the investments by                     
          petitioner in hedge transactions, repayments of principal and               
          interest to managed account investors, transfers to GSC, or other           
          amounts that petitioner paid on behalf of GSC.                              
               On February 13, 1991, respondent’s notice of deficiency for            
          1986 was mailed to petitioner in which notice $6,033 of claimed             
          interest expenses was disallowed.                                           










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