Kondamodi S. Rao and B. Satyaveni Rao - Page 5

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          Kondamudi Enterprises, Inc., used to make mortgage payments on              
          the medical center.  A fourth account at Chase Manhattan Bank               
          (Chase) was used to pay an equipment loan from Chase during the             
          years in issue.                                                             
               On petitioners' income tax returns for the years 1986, 1987,           
          and 1988, petitioners reported on Schedule C gross receipts from            
          Dr. Rao's private practice of psychiatry in the amounts of                  
          $135,162, $170,569, and $212,522, respectively.  In fact, Dr. Rao           
          received gross receipts from his psychiatry practice during the             
          years 1986, 1987, and 1988 in the amounts of $175,507, $220,408,            
          and $259,637, respectively.  Petitioners failed to report                   
          Schedule C gross receipts from Dr. Rao's psychiatry practice in             
          the years 1986, 1987, and 1988 in the amounts of $40,345,                   
          $49,839, and $47,115, respectively.                                         
          Dr. Rao's Record Keeping                                                    
               Petitioner kept no books or records; he did not reconcile              
          his checking accounts against bank statements or check bank                 
          deposits against his monthly bank statement.  Petitioner did not            
          deduct outstanding checks from his checking account to determine            
          the amount of funds available in the checking account.                      
          Petitioner never received any instruction in bookkeeping or                 
          accounting in a school, nor had petitioner ever practiced with              
          another professional.                                                       








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