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.
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