- 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