- 5 - $31,200.75, and $37,833.89 in 1984, 1985, 1986, and 1987, respectively. On April 6, 1994, respondent issued a notice of deficiency to petitioner. Respondent used the net worth method of income reconstruction to determine petitioner's taxable income for the years in issue. For each of these years, respondent determined that petitioner's net worth, increase in net worth, total net worth, and personal living expenses were as follows: 01/01/84 12/31/84 12/31/85 12/31/86 12/31/87 Total assets $330,568 $502,423 $570,027 $350,432 $281,967 Total liabilities (53,920)(70,173) (64,598) (51,563) (45,024) NET WORTH 276,648 432,250 505,429 298,869 236,943 Net worth at beginning of year -- (276,648) (432,250) (505,429)(298,869) Increase in net worth -- 155,602 73,179 (206,560) (61,926) Personal living expenses -- 44,111 46,812 1319,358 136,977 ECONOMIC INCREASE -- 199,713 119,991 112,798 75,051 1 Petitioner's personal living expenses included gifts to his children of $281,294.86 in 1986 and $104,089.55 in 1987. Based on these computations, respondent calculated that petitioner had gross income of $199,713.04, $119,990.50, $112,798.82, and $75,050.67 for 1984, 1985, 1986, and 1987, respectively. Based on these amounts, respondent determined that petitioner was liable for deficiencies of $78,807.11, $41,092.63, $36,949.80, and $16,621.39 for 1984, 1985, 1986, and 1987, respectively. The deficiencies included self-employment tax ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
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