Estate of David J. Dickerson, Deceased, Dorothy Dickerson, Executor and Dorothy Dickerson, et al. - Page 33

                                       - 33 -                                         
          have personal expenditures or that the amounts paid for personal            
          expenditures came from nontaxable sources.                                  
               Michoff, Jr., has the burden of proving that respondent's              
          determinations are in error.  Rule 142(a).  He has failed to meet           
          this burden with regard to any of the amounts determined to be              
          unreported income.  Respondent is sustained on this issue.                  
          Unreported Income--Michoff,Jr., and Kimberly Michoff                        
               Michoff, Jr., and Kimberly Michoff filed a joint Federal               
          income tax return for the 1990 tax year.                                    
               Respondent's revenue agent conducted a bank deposits                   
          analysis of the 1990 tax year of Michoff, Jr., and Kimberly                 
          Michoff.  Based on this analysis, respondent, after concessions,            
          argues on brief that Michoff, Jr., and Kimberly Michoff had                 
          unreported income of $22,649 in the 1990 tax year.  Petitioners             
          concede the deposits in 1990 but claim that they were transfers             
          from accounts, loans, and gifts and that some of the amounts were           
          duplicated by the revenue agent and counted more than once.                 
               The amount that Michoff, Jr., and Kimberly Michoff spent on            
          personal expenditures by check was subtracted from the bank                 
          deposits total.  Michoff, Jr., and Kimberly Michoff made deposits           
          into their First Interstate Bank account in the amount of $3,187            
          which is in issue in the 1990 tax year.  This amount is not the             
          total amount of deposits into this account in the 1990 tax year.            
               The Michoff, Jrs., made deposits into their Placer Savings             
          Bank accounts in the amount of $18,892 in the 1990 tax year.                

Page:  Previous  23  24  25  26  27  28  29  30  31  32  33  34  35  36  37  38  39  40  41  42  Next

Last modified: May 25, 2011