- 6 -
adjustments totaling $83,845. Consistent with the determinations
in the notice of deficiency for 1986 and 1987, respondent
determined that, for 1988, petitioner was required, under
California's community property law, to include in her income
one-half of the net income, or $40,415, of Sharer Accountancy,
her late husband's accounting proprietorship. Other adjustments
totaled $25,205, which included automobile allowances paid to
petitioner by Gold Country, unaccounted and unexplained deposits
to petitioner's bank accounts, and personal expenses of
petitioner paid by a third party. Respondent also determined
that $20,000 petitioner received from a law firm during 1988, as
well as a State income tax refund of $1,312, constituted gross
income. All of these adjustments, except for the $40,415 from
Sharer Accountancy, were based upon bank records and information
provided to respondent by payors.
Petitioner filed her petition on October 9, 1992, contesting
the deficiency notice for 1988. On December 10, 1992, respondent
filed an answer. On September 27, 1993, an Appeals Officer of
respondent mailed a letter to petitioner's attorney setting out
the issues and inviting the attorney to submit evidence in
support of petitioner's case, noting that the case was calendared
for trial on January 24, 1994. Respondent also suggested that
petitioner sign a Stipulation to be Bound by the finding of the
Court for tax years 1986 and 1987 with respect to the issue of
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011