- 9 - petitioners' check exchange involvement with M&L. Careswell was unable to reconcile petitioners' deposits with their records and found that the records were inadequate. Therefore, Careswell turned to a bank deposits analysis to reconstruct petitioners' income from all sources, including the involvement with M&L and the jewelry business. Using the bank deposits analysis, Careswell calculated total deposits of $4,898,961 and subtracted nontaxable deposits of $1,148,549 and the income reported by petitioners of $594,374. To that amount he added cash and other income items of $34,646 to arrive at taxable deposits not reported of $3,190,684. Careswell then made a further reduction of $2,571,129, representing petitioners' payments and transfers to M&L under the check kiting scheme. This resulted in net unexplained bank deposits of $619,555 for 1990. The $2,571,129 amount by which Careswell reduced the unexplained bank deposits was determined from his check spread analysis of check exchanges with M&L. Careswell's analysis reflects $3,263,124 remitted by M&L to petitioners and $2,571,129 remitted by petitioners to M&L for a net excess to petitioners of $691,995 for 1990. Petitioners argue that their unreported taxable income should be determined using the net difference from the check spread analysis reduced for certain adjustments asserted by petitioners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011