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Risner Chiropractic Clinic and the Risner Family Trust. Although
petitioner appeared before Revenue Agent Southern at the date and
time specified in the summons, he refused to produce his books
and records on the grounds that to do so would violate his rights
under the Fourth and Fifth Amendments to the U.S. Constitution.
By notice of deficiency dated June 21, 1995, respondent
determined deficiencies, additions to tax, and a penalty with
respect to petitioner's Federal income taxes for the years and in
the amounts as follows:
Additions to Tax Penalty
Year Deficiency Sec. 6651(a) Sec. 6654(a) Sec. 6662
1992 $44,306 $5,989 --- $8,861
1993 38,279 9,570 --- ---
1994 28,661 7,165 $1,487 ---
The explanation of adjustments portion of the notice of
deficiency states that respondent arrived at petitioner's taxable
income by (1) increasing petitioner's interest and dividend
income to account for third-party information reported to
respondent on Forms 1099-INT and 1099-DIV,2 and (2) computing
petitioner's net income from his chiropractic business using
petitioner's prior earnings experience in conjunction with the
applicable Consumer Price Index factors for the years 1992, 1993,
and 1994. Using $75,139 (the net profit figure reported by
petitioner on the Schedule C attached to his 1991 tax return) as
2 Respondent received third-party information (including
Forms 1099-INT and 1099-DIV) indicating that petitioner invested
substantial amounts in several different stock and bond mutual
fund accounts during 1992 and 1993.
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