Lota Womack - Page 11

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          Form W-2 as she had done in each previous year of their marriage.           
          No separate return was filed by petitioner for 1990.                        
          Examination of Returns                                                      
               Respondent examined the 1989 and 1990 returns and, on                  
          September 9, 1993, mailed a separate notice of deficiency to each           
          of the spouses who were at that time again separated and in the             
          process of divorcing.  Respondent determined the following                  
          increases (decreases) in income:                                            
                    Item                     1989           1990                      
               Income                        $15,982        $10,263                   
               Business expenses             3,329          23,853                    
               Depreciation                  (3,822)        (5,755)                   
               Early withdrawal penalty      (311)                                    
               Self-employment tax deduction                (1,952)                   
               Itemized deductions                          1,981                     
                    TOTAL                    $15,178        $28,390                   
               Respondent used the bank deposits method to determine                  
          unreported income.  In determining the omitted income of $15,982            
          and $10,263, respondent took into account petitioner's W-2 wage             
          income, Mr. Womack's W-2 wage income, the loans from petitioner's           
          father and Joe Stroup, and the miscellaneous income items                   
          discussed above; the omitted income was in addition to all of               
          those known sources.                                                        
               The parties have stipulated that the Commissioner "has                 
          accepted an aggregate amount of Schedule C expenses and cost of             
          goods sold and/or operations paid by David Womack" for the                  
          property services business in the amount of $31,225 for the year            





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