Maurzal Frias and Teresa Frias - Page 4

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          Bank of Oklahoma         5          ---              ---                    
          Total          76,464              67,644         67,379                    
          Schedule C gross receipts reported on petitioners' 1991 tax                 
          return were $57,501.  "Total Income", as recalculated by Mr.                
          Gardner after the start of the audit, for 1991 was $64,281.                 
          Petitioners made cash deposits--not to be confused with withheld            
          cash--during 1991 of $3,090.  Mr. Gardner did not consider these            
          cash deposits as part of petitioners' Schedule C gross receipts.            
          Respondent determined that petitioners had underreported their              
          gross receipts for 1991 by $9,733.  (Respondent did not consider            
          all deposits to be gross receipts; her revenue agent backed out             
          loan proceeds, account transfers, and gifts.)                               
               A summary of total deposits, as calculated by the IRS, Mr.             
          Gardner, and petitioners, for 1992 follows:                                 
                              Respondent's                  Petitioners'              
                              Audit          Mr. Gardner    Check Registers           
          Bank of Oklahoma    $63            $2,448         $2,492                    
          Withheld cash       520          ---              ---                       
          Bank of Tulsa       68,398         68,348         48,886                    
          Withheld cash     4,029          ---              ---                       
          Sooner Fed. S&L     11,570         11,115         7,796                     
          Withheld cash       935          ---              ---                       
          Total          85,515              81,911         59,174                    
          Schedule C gross receipts reported on petitioners' 1992 tax                 
          return were $61,553.  "Total Income", as recalculated by Mr.                
          Gardner after the start of the audit, for 1992 was $66,345.                 
          Petitioners made cash deposits during 1992 totaling $16,476.                
          These cash deposits were not considered as part of petitioners'             
          Schedule C gross receipts as recalculated by Mr. Gardner.                   



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