- 5 -
of documents at the proper address. Petitioner did not respond
to this motion.
Shortly before the trial opened, the Great Western Bank,
pursuant to a summons, provided respondent with bank records.
The records reveal that, during the years in issue, petitioner
maintained a Great Western Bank account in the name of "Warren R.
Ketler, D.B.A. Thru The Lens". The signature card for the
account used petitioner's Social Security number and address.
Thru The Lens is a photography business. Bank statements of this
account, No. 308-8083971, reveal total deposits of $8,563 for
petitioner's taxable year 1990 and $23,691 for 1991.
The summoned records also reveal that petitioner had a
separate individual account at Great Western Bank, No. 308-
8064948, maintained under his own Social Security number and
mailing address. Statements of this account reveal total
deposits of $80,609 for 1990 and $39,467 for 1991. Petitioner
commingled the income and expenses of Thru The Lens between
account Nos. 308-8083971 and 308-8064948.
Respondent then reconstructed petitioner's income on the
basis of these bank records. Respondent determined that some of
the deposits into the Thru The Lens account were not accessions
to income but rather transfers from petitioner's individual
account. These transfers totaled $2,900 in 1990 and $1,000 in
1991. Respondent further determined that some expenditures from
the Thru The Lens account were deductible business expenditures;
these totaled $4,499 for 1990 and $6,168 for 1991.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011