- 3 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 Next
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