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For all of the years in issue, petitioner made his return of
Federal income tax on the basis of a calendar year. Petitioner
filed his 1987 Federal income tax return on July 6, 1988.
II. Disputed Adjustments
A. Unreported Income
In her notice of deficiency, respondent made adjustments
increasing petitioner's gross income for 1986, 1987, and 1988 on
account of certain unexplained bank deposits and cash
transactions. Petitioner does not dispute that the bank deposits
in question were made to accounts owned by him or that he
received the cash items in question. He claims, however, that
virtually all of those items were either loan repayments or
redeposits of cash carried around by petitioner on his person
and, thus, not items of gross income. We shall address the items
in question year by year.
1. 1986
During 1986, petitioner owned a bank account at North Fork
Bank and Trust Co., Southampton, New York (North Fork), account
No. 141568791 (the North Fork account). On the dates and in the
amounts indicated, petitioner made the following deposits to the
North Fork account:
Date Amount
5/15/86 $5,800
8/25/86 900
10/21/86 3,000
10/29/86 5,000
Total $14,700
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