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v). During the taxable year 1994, the petitioner
did not receive any non-taxable gifts.
w). During the taxable year 1994, the petitioner
did not receive any non-taxable inheritances.
x). During the taxable year 1994, the petitioner
did not receive any non-taxable loans to make the
expenditures reflected in respondent’s reconstruction
of petitioner’s source of funds.
y). During the taxable year 1994, the petitioner
did not rely on a cash hoard, refund, or any other non-
taxable source for the making of the expenditures
reflected in respondent’s reconstruction of his income.
z). During the taxable year 1994, the petitioner
made expenditures in the amount of at least $72,731, as
follows:
Down payment on residence at 4117 Muriel Place $ 12,862
Commission paid to real estate agent on purchase 500
Escrow deposit on above purchase 2,000
1993 tax amounts paid in 1994 5,800
Furnishings from Roberd’s 12,565
Gold jewelry (810 pennyweight @ $16 each) 12,960
Tax return preparation fees 1,800
Payments on 1993 Toyota 4-Runner 6,245
Personal living expenses per BLS for 1 person 17,999
Total $ 72,731
aa). Against his unreported income of $72,731,
petitioner was entitled to a personal exemption of
$2,450 a self-employment tax deduction of $4,731, and a
standard deduction of $3,800.
ab). Accordingly, for the taxable year 1994,
petitioner failed to report his receipt of taxable
income in the amount of at least $61,750, all with
fraudulent intent to underpay his income taxes for
1994.
ac). For the taxable year 1994, the petitioner’s
taxable income, his taxable income as reported on his
return, and his understatement of taxable income, were
as follows:
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