- 3 - Petitioners maintained four bank accounts, two at the Bank of Oklahoma, one at the Bank of Tulsa, and one at Sooner Federal Savings and Loan. During an audit of petitioners' 1991 and 1992 Federal individual income tax returns (tax returns), the revenue agent analyzed petitioners' bank deposits and determined that petitioners had underreported their gross income. Petitioners did not report any income from magic shows or band activities on their tax returns. After the audit began, Mr. Gardner prepared detailed schedules of petitioners' bank deposits, including a calculation of "total income", for the 1991 and 1992 years. Cash withheld from deposits3 was reflected on Mr. Gardner's schedules but was not included in the total deposits. Petitioners maintained check registers. The deposits recorded in petitioners' check registers do not include cash withheld from the deposits. A summary of total deposits, as calculated by the IRS, Mr. Gardner, and petitioners, for 1991 follows: Respondent's Petitioners' Audit Mr. Gardner Check Registers Bank of Oklahoma $18,585 $18,707 $18,711 Withheld cash 2,320 --- --- Bank of Tulsa 33,226 34,956 35,097 Withheld cash 6,930 --- --- Sooner Fed. S&L 13,982 13,981 13,571 Withheld cash 1,416 --- --- 3 When petitioners deposited checks, they often withdrew cash, depositing less than the amount of the check.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011