- 10 - none of the requested documents was provided to the agent. The agent then summonsed petitioner's bank records on January 7, 1993. On February 3, 1993, petitioner's attorney sent a letter to the agent indicating that a response from petitioner was enclosed with the letter. The record, however, does not include petitioner's response. On April 7, 1993, respondent issued a notice of deficiency for petitioner's 1989 tax year. Based on information derived from bank records and information obtained from audits of related taxpayers, respondent determined net income adjustments totaling $35,403. By far, the largest adjustment was additional income totaling $42,831, which consisted essentially of the same kind of items as generated the $25,205 adjustment for petitioner's 1988 tax year.5 Other adjustments included $150 taxable Social 5 Specifically, the items consisted of: $ 3,000 Automobile allowance paid to petitioner by Gold Country 9,580 Checks from petitioner's mother deposited in petitioner's checking account 800 A deposit of currency in petitioner's checking account 25,258 Deposited into petitioner's M & B Investment Club account 3,904 Adjustment for personal living expenses 7,449 Amount received for sale of the Sharer Accountancy client list $49,991 TOTAL Since petitioner had reported $7,160 of the above items as Schedule C trade or business income, the $42,831 adjustment represented net unreported income.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