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Year Unreported Income
1984 $287,081
1985 275,446
1987 255,290
At trial and in her briefs, respondent has made revisions to
the above determination of unreported income, as reflected below:
Respondent's Revised
Determination of Petitioner’s
Year Unreported Income
1984 $263,054
1985 192,399
1987 244,449
Total $699,902
For 1984, 1985, and 1987, respondent did not allow as
business expenses or otherwise give petitioner credit against any
of the bank deposits that respondent treated as unreported
taxable income to petitioner, any of the investments by
petitioner in hedge transactions, repayments of principal and
interest to managed account investors, transfers to GSC, or other
amounts that petitioner paid on behalf of GSC.
On February 13, 1991, respondent’s notice of deficiency for
1986 was mailed to petitioner in which notice $6,033 of claimed
interest expenses was disallowed.
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