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of the year. Third-party records, petitioners' depreciation
schedules, and Department of Motor Vehicles' records were used to
calculate petitioners' ownership of personal property.
Respondent computed petitioners' increase in the ownership
of real property by determining the real property owned at the
end of the year less what was owned at the beginning of the year.
Respondent obtained the records relating to petitioners'
acquisition of real property from third-party sources.
Respondent used amortization tables to calculate loan balances at
the end of each taxable year.
All payments from petitioners' personal bank accounts on
credit card account balances were treated as personal living
expenses in respondent's computation of petitioners' net worth.
Respondent determined petitioners' February 1, 1990,
investment in JKY by netting assets and liabilities transferred
to JKY as follows:
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