- 4 -
Issue 1. Unreported Income
FINDINGS OF FACT
Petitioner has been a certified public accountant since
1973. In 1987 he left his employment at Coopers and Lybrand and
started his own business, which he maintained during the years at
issue. At the time of trial, petitioner was employed by B.D.O.
Seidman in San Francisco as a senior manager in the audit
department. During the years in issue, petitioner billed clients
on an hourly basis, and periodically he sent invoices to his
clients. He deposited payments into his bank accounts.
Petitioner kept no formal set of books for 1988 or 1990. As
a consequence, respondent determined petitioner's income for
those years using the bank deposits analysis method.
The following is a summary of respondent's bank deposit
analysis for 1988:
Page: 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