- 8 - In passing, we note the stipulation of the parties that the ending deferred interest as calculated by respondent in the amount of $3,091,395.88 should be increased by $437,800. We also note the stipulation that the earned interest as calculated by respondent in the amount of $3,084,170 should be increased by $295,200. In this opinion, we shall continue to refer to the amounts originally calculated by respondent and used in the notice of deficiency in order to avoid confusion. Based upon the agent's analysis, respondent determined that petitioner's interest income had been understated in the amount of $3,084,179.12. Respondent also determined that petitioner's interest income had been understated by the difference between the aggregate deferred interest computed from the ledger cards as shown above, $6,175,575, and the deferred interest shown on petitioner's books and records, $7,772,543, or $1,596,968. Accordingly, respondent determined that petitioner's interest income had been understated in the aggregate amount of $4,681,147 (i.e., $3,084,179 plus $1,596,968). During the audit, respondent's agent asked Mr. Cordes to provide certain information pertaining to petitioner's bank deposits at Citizens Bank in Lawton, Oklahoma. Mr. Cordes refused the agent's request. Accordingly, the agent issued an administrative summons to obtain thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011