Mary Lee Sharer - Page 10

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          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.                                                 
                                                                                            




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