Willie Thomas - Page 5

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          $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 of             









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