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amounts of $55,097 and $2,800 for the tax years 1989 and 1990,
respectively.4
The Dickersons made specific payments on their Primeline
credit account in the total amount of $9,200, which is in issue
in the 1989 tax year. These were not, however, the total
payments made by the Dickersons on their Primeline credit account
in the 1989 tax year.
The Dickersons made deposits into their El Dorado savings
account in the amounts of $37,100 and $2,800 in the 1989 and 1990
tax years, respectively. These were not the total deposits made
into this account in the 1989 and 1990 tax years.
Respondent also identified a cash expenditure which she
added to the unreported income of the Dickersons for the 1989 tax
year. This expenditure was the purchase of a cashier's check in
the amount of $8,797 for purposes of purchasing the Green Ridge
Drive residence.
Petitioners argue that the $8,797 cashier's check was
purchased with loans from Dan Maggard. However, the check from
Dan Maggard was deposited into the El Dorado account.
Petitioners failed to show a canceled check that was used to
4 Petitioners objected to respondent's proposed finding of
fact which reads as follows: "Respondent's revenue agent
conducted a bank deposits analysis of the Dickerson's income for
1989 and 1990." On brief, however, petitioners do not dispute
that respondent's revenue agent conducted a bank deposits
analysis; rather they argue that it was conducted improperly.
This is typical of the argumentative and contradictory statements
that appear throughout petitioners' briefs.
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