Relying on certain transactions with respect to the above accounts, respondent determined that petitioners' gross receipts for the years in issue were as follows: 1985 1986 1987 $263,609 $570,874 $90,646 In her answer, respondent asserted an increased deficiency of $22,448 for 1986 based upon additional funds that were transferred from Marine Midland Bank--account no. 921-11974-7 to Ard Rhei, but which had not been included in income pursuant to the notice of deficiency.7 The banking transactions upon which respondent's notice of deficiency and claimed increase in deficiency are based are summarized8 as follows: Bank Account Account Transaction Name Number Title Type 1985 1986 1987 Marine 921-13312-0 John J. Burke checks to $41,800.00 $4,000.51 Midland & Assoc. Balsamo, John MPC Premium Burke, cash, A/C Jury's, and Tobin Marine 921-69297-8 John J. Burke cash $53,500.00 50,500.00 31,400.00 7The claimed increased deficiency is based upon the following checks drawn on Marine Midland Bank account no. 921-11974-7 (John J. Burke & Associates): Date Check no. Amount Endorsement 06/02/86 1472 $5,000 Ard Rhei/Jury's 11/18/86 1739 2,500 Ard Rhei 11/19/86 1742 2,500 Ard Rhei 12/01/86 1750 1,548 Ard Rhei 12/03/86 1753 3,200 "For Deposit Only" 12/11/86 1761 4,300 Ard Rhei 12/16/86 1770 2,200 Ard Rhei 12/23/86 1781 1,200 Ard Rhei Total $22,448 8A description of specific transactions upon which this summary is based is contained in the Appendix.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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