Gregg H. Risner - Page 3

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          Risner Chiropractic Clinic and the Risner Family Trust.  Although           
          petitioner appeared before Revenue Agent Southern at the date and           
          time specified in the summons, he refused to produce his books              
          and records on the grounds that to do so would violate his rights           
          under the Fourth and Fifth Amendments to the U.S. Constitution.             
               By notice of deficiency dated June 21, 1995, respondent                
          determined deficiencies, additions to tax, and a penalty with               
          respect to petitioner's Federal income taxes for the years and in           
          the amounts as follows:                                                     
               Additions to Tax          Penalty                                      
          Year  Deficiency  Sec. 6651(a)   Sec. 6654(a)   Sec. 6662                   
          1992   $44,306       $5,989           ---         $8,861                    
          1993    38,279        9,570           ---            ---                    
          1994    28,661        7,165         $1,487           ---                    
          The explanation of adjustments portion of the notice of                     
          deficiency states that respondent arrived at petitioner's taxable           
          income by (1) increasing petitioner's interest and dividend                 
          income to account for third-party information reported to                   
          respondent on Forms 1099-INT and 1099-DIV,2 and (2) computing               
          petitioner's net income from his chiropractic business using                
          petitioner's prior earnings experience in conjunction with the              
          applicable Consumer Price Index factors for the years 1992, 1993,           
          and 1994.  Using $75,139 (the net profit figure reported by                 
          petitioner on the Schedule C attached to his 1991 tax return) as            



               2  Respondent received third-party information (including              
          Forms 1099-INT and 1099-DIV) indicating that petitioner invested            
          substantial amounts in several different stock and bond mutual              
          fund accounts during 1992 and 1993.                                         


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