- 26 -
cashier’s checks for the purchase of a home placed in his wife’s
name, living and other personal expenditures.
The controverted cashier’s checks total $25,000, which,
initially, would indicate a shortfall of about $4,000 between
McDonald’s sources and applications. Further, McDonald’s
analysis does not account for living expenses. Finally,
McDonald’s analysis of the possible sources is offered in a
vacuum and does not account for undeposited receipts from
clients. Again, petitioners’ intentional discarding of the
accounts receivable information and the concealment of the
identity of their clients is the reason the source analysis is
not complete or reliable.
Under these circumstances, we find that petitioners have not
carried their burden. Hence, respondent’s determination that the
various checks and cash items are income to petitioners is
sustained.
Self Employment Tax--To the extent that additional income is
determined in these cases, petitioners agreed on brief that any
increase in self-employment tax is merely computational.
Respondent determined that additional income was derived from
petitioners’ practice of tax accounting. Such income of
petitioners is subject to self-employment tax.
Taxability of McDonald’s Social Security Benefits--This
appears to be a computational item that is dependent on the
parties’ agreement to be bound by the final outcome of an earlier
case regarding whether McDonald was married for tax purposes
Page: Previous 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 NextLast modified: May 25, 2011