- 16 -- 16 - general contracting business. Petitioners did not report in Schedule C, or elsewhere, in their return for that year income from any business other than Charles Harp Construction. Petitioners did not include as income in their returns for 1989 and 1990 any portion of K & H's and Ms. Velilla's funds that petitioner deposited into petitioners' accounts during those years. Nor did they include in their returns for those years any income in connection with the Kabeiseman loans. The Examination of Petitioners' 1989 and 1990 Returns and the Notice of Deficiency In June 1993, respondent assigned a revenue agent to examine petitioners' returns for 1989 and 1990. During the course of that examination, the revenue agent did not have sufficient books or records relating to petitioner's sole proprietorship or petitioners' other financial activities during the years at issue in order to determine whether petitioners had reported in those returns all of their income for those years, nor did petitioners attempt during the course of that examination to re-create any of the books or records relating to their financial activities dur- ing the years at issue that they claim were accidentally dis- carded during 1991. Consequently, in order to reconstruct peti- tioners' income for the years at issue, the revenue agent used the bank deposits method under which that agent examined the deposits that were made during those years into petitioners' accounts at various financial institutions. Based on certainPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
Last modified: May 25, 2011