- 4 - joint names of petitioner and his wife. The revenue agent served a summons upon each of the banks to produce statements showing deposit and withdrawal activity for each of petitioner's accounts. On September 1, 1993, petitioner filed a petition to quash respondent's summons of his bank records. The petition to quash alleged that respondent committed fraud and misrepresentation in obtaining the summons because the summons itself was not issued by the Secretary. On February 4, 1994, the U.S. District Court for the District of Columbia held that the petition to quash was meritless and ordered summary enforcement of the summons. After obtaining the bank statements,3 respondent's revenue agent determined the amount of income received by petitioner based on the deposits to the various accounts. Included in the bank deposits made by petitioner were payments he received as a public insurance adjuster during the years at issue. Also included in the bank deposits were two checks totaling $38,967, which petitioner received on April 7, 1989, from the City of Baltimore for professional services rendered to the city. To the extent respondent's revenue agent could verify transfers between petitioner's accounts, the revenue agent reduced the income calculation by each amount which was transferred between accounts 3All the monthly bank statements were obtained by the revenue agent except for the August 1987 statement. Respondent's revenue agent estimated the amount of August deposits by using a weighted average of all the deposits in that year.Page: Previous 1 2 3 4 5 6 7 8 9 Next
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