Miriam Lawrence - Page 16

                                                 - 16 -16                                                     
            The deficiency resulted from the following adjustments to their                               
            income:                                                                                       

                        Description                                1987                                   
                  Gross receipts                              $1,661,551                                  
                  Interest expense-Sch. C                     116,321                                     
                  Schedule C expenses: attorney       225,054                                             
                  Schedule C expenses: La Posta         37,286                                            
                  Schedule E: Fall Mansion                    40,202                                      
                  Capital gains and losses                    407,576                                     
                  Itemized deductions                         (11,351)                                    
                  The bases for the adjustments made in the notices of                                    
            deficiency were the conclusions formed by Agent Red as a result                               
            of his examinations.                                                                          
            V.  The Docketed Cases                                                                        
                  The petitions were filed in these cases on February 27,                                 
            1992.  In each case petitioners assigned error to all of the                                  
            adjustments made in the notices of deficiency.                                                
                  With respect to the omitted income adjustment, in her                                   
            petition Lawrence alleged that "the revenue agent used the bank                               
            deposit method to determine that petitioner had realized                                      
            additional income without any inquiry of petitioner to identify                               
            the nature of the deposits."   Likewise, the Abrahams, in an                                  
            amendment to their petition, alleged that the "unreported income                              
            was determined under the bank deposit plus cash expenditure                                   
            method without inquiry into non-taxable transfers and loans, no                               








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