- 10 - Revenue Service (Nahmias) conducted an independent investigation. Nahmias traced the stolen cars to the third-party used car dealers who purchased them and determined the amounts paid to petitioner for these cars. He interviewed the dealers involved and reviewed the canceled checks, the falsified new car invoices, and the loan payments. Nahmias allowed petitioner deductions of $18,324.27 and $56,036.34 for 1966 and 1967, respectively, for the deposits, loan payments, and insurance expenses on the stolen cars. For the taxable year 1966, respondent determined that petitioner had failed to report $5.73 in interest income and $37,636.73 in net income from the sale of the stolen cars,4 resulting in a deficiency in tax of $14,374.82. Respondent also determined an addition to tax for fraud under section 6653(b) in the amount of $8,113.44. Respondent issued the notice of deficiency for taxable year 1966 on February 5, 1993. Revenue Agent Metz (Metz) prepared a corporate return for the Stables for the taxable year 1967. Metz had none of the Stables' business records, so he calculated income and expenses through inquiries to third-party sources. Metz used the American Racing Manual Statistics to determine the amounts won by the 4 The net income figure represents: Income from car sales $42,050.00 Income from car sales 13,911.00 Total income $55,961.00 Total expenses - 18,324.27 Net income $37,636.73Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011