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Month Total Deposits Into Checking Account
1993 1994 1995
January -0- $ 21,346 $ 10,533
February $ 28,154 34,950 19,056
March 25,824 12,150 23,104
April 37,400 53,022 18,000
May 20,131 44,211 21,372
June 48,870 55,007 61,050
July 34,149 37,700 49,146
August 33,038 17,577 670
September 52,000 53,619 24,465
October 91,020 51,219 51,946
November 72,000 56,580 17,492
December 65,150 40,450 34,500
Total $507,736 $477,903 $331,334
For 1993, 1994, and 1995, petitioner did not file Federal
income tax returns.
During respondent’s audit, petitioner did not cooperate with
respondent’s agents, and petitioner did not provide to
respondent’s agents the books and records relating to the roofing
business. Also, petitioner mailed to respondent letters
reflecting frivolous tax protester arguments.
On audit and in the notices of deficiency for the years in
issue, using the bank deposits method of proof and the specific
item method of proof for interest income earned on the checking
account balance, respondent determined that petitioner received
unreported taxable income in the following total amounts:
Year Amount
1993 $517,236
1994 477,903
1995 333,780
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Last modified: May 25, 2011