Robert G. Bacon and Barbara Bacon - Page 12




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               10We note that respondent’s proposed adjustment to petitioners’ 1990   
          taxable income is $18,865 more than what we arrive at when subtracting the  
          agreed upon adjustments to the bank deposit analysis from respondent’s initial
          computations under the bank deposit analysis. ($500,851 - $140,101 - $379,615
          = $18,865)                                                                  
               11We note that respondent’s proposed adjustment to petitioners’ 1991   
          taxable income is $86 less than what we arrive at when subtracting the agreed
          upon adjustments to the bank deposit analysis from respondent’s initial     
          computations under the bank deposit analysis. ($236,417 + $8,997 - $245,328 =
          $86)                                                                        
               With the exceptions noted below (see infra notes 13, 14, and           
          15), respondent’s final bank deposits analysis, as adjusted                 
          pursuant to the parties’ stipulations, is supported by the facts.           
          On the basis of stipulated facts and evidence admitted at trial,            
          we find that petitioners had unreported income of $102,74813 in             
          1988, $320,66114 in 1989, $358,21515 in 1990, and $245,328 in               
          1991.                                                                       
               Petitioners argue that respondent’s bank deposit method is             
          fundamentally flawed.  Admittedly, there have been a significant            



               13We eliminated a $5,007 item in respondent’s bank deposit             
          analysis for corporate expenditures on petitioners’ behalf                  
          because the proposed adjustment was not supported by the record.            
          The omission has the effect of reducing petitioners’ unreported             
          income by $5,007.                                                           
               14We eliminated an $860 item in respondent’s bank deposit              
          analysis for corporate expenditures on petitioners’ behalf                  
          because the proposed adjustment was not supported by the record.            
          The omission has the effect of reducing petitioners’ unreported             
          income by $860.                                                             
               15We eliminated a $2,535 item in respondent’s bank deposit             
          analysis for corporate expenditures on petitioners’ behalf                  
          because the proposed adjustment was not supported by the record.            
          The omission has the effect of reducing petitioners’ unreported             
          income by $2,535.  We also reduced respondent’s final computation           
          of unreported income by $18,865.  This is the amount by which               
          respondent’s final unreported income determination exceeds the              
          amount arrived at pursuant to the stipulated adjustments to the             
          notice of deficiency.  (See supra p.11, table note 10.)                     



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