Robert D. Grossman, Jr. - Page 133

                                                                 - 76 -                                                                       

                         Table 13 sets forth petitioner’s and Betsy’s 1983 adjusted                                                           
                gross income, taxable income, and income tax liability as (1)                                                                 
                shown on their 1983 tax return, (2) adjusted by respondent in                                                                 
                1987, and (3) determined in the notice of deficiency in the                                                                   
                instant cases.                                                                                                                
                                                                Table 13                                                                      
                                                                                     1987                                                    
                                                                             Audit--Revenue     Notice of                                    
                                                     Tax Return               Agent’s Report     Deficiency1                                  
           Adjusted gross income                     $407,347                           2                                                     
                                                                                                               2                              
           Taxable income                            354,112                  $284,227                         $309,497                       
           Income tax liability                      160,344                  125,402                          138,142                        

                1 These amounts are as shown in the notice of deficiency, and do                                                              
                not take into account respondent’s later concessions.  See supra                                                              
                note 2.                                                                                                                       
                2 Adjusted gross income is not shown on the indicated documents.                                                              
                         Respondent audited petitioner’s and Betsy’s 1985 joint tax                                                           
                return sometime before February 1987, and concluded that                                                                      
                petitioner and Betsy had overstated their income for that year by                                                             
                $18,033; this overstatement resulted in a $9,016 overstatement of                                                             
                petitioner’s and Betsy’s 1985 tax liability.  The resulting Form                                                              
                4549 (Income Tax Examination Changes) for 1985 shows that                                                                     
                petitioner and Betsy were entitled to a $8,333 increase in                                                                    
                deduction for “Rental Expenses” and a $9,700 increase in                                                                      
                deduction for “Contributions”.  Apparently, petitioner and Betsy                                                              






Page:  Previous  66  67  68  69  70  71  72  73  74  75  76  77  78  79  80  81  82  83  84  85  Next

Last modified: May 25, 2011