Khosrow Ghadiri and Turan Mirhady Ghadiri - Page 7

                                        - 7 -                                         
            Mrs. Ghadiri   $360      - 0 -      $1,600    $1,960                      
            Maple Press    - 0 -    $10,922     - 0 -     10,922                      
            Print                                                                     
            Technology    13,725      6,050      - 0 -        19,775                  
          Total     14,085           16,972     1,600     32,657                      

          For their 1988 taxable year, petitioners received but did not               
          report interest income of $9.                                               
               Respondent used a bank deposits analysis to reconstruct                
          petitioners' income for 1986, 1987, and 1988.  Respondent                   
          determined that petitioners' print shops' checking accounts had             
          total deposits of $485,974, $394,648, and $295,085 for 1986,                
          1987, and 1988, respectively.  The notice did not specifically              
          mention "Maple Press" even though the deficiencies determined in            
          the notice of deficiency for 1986, 1987, and 1988 took into                 
          account only gross receipts from Maple Press.  Following                    
          discussions with petitioners, respondent adjusted petitioners'              
          deficiencies to include in their gross income gross receipts from           
          Acacia Press and Print Technology.  Although respondent included            
          the gross receipts from additional stores in making her                     
          revisions, the deficiencies for 1986 and 1987 are lower, as a               
          result of respondent's adjustments, than originally determined              
          because respondent gave petitioners credit for additional                   
          inter-account transfers and ordinary and necessary business                 
          expenses.                                                                   
               Mr. Ghadiri received a bachelor's degree in electrical                 
          engineering at the University of California at Berkeley, a                  





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