- 4 - thus depleted and moved the ammunition box to a new location unknown to petitioner. For reasons not disclosed in the record, the criminal investigation was discontinued later that year and the case referred to the Examination Division of the IRS. The audit of petitioner’s 1989 and 1990 returns was conducted by Revenue Agent Elizabeth Duffy (Duffy). Petitioner did not show Duffy any records. In the absence of records, Duffy reconstructed petitioner’s income using the source and application of funds method. Under this method, she determined the total amount of petitioner’s expenditures plus bank deposits in 1989 and 1990 and the total amount of funds available to him from identified sources in each year. In computing petitioner’s available resources, Duffy included the $16,383 and $21,698 of receipts traceable to farm sales but not reported on petitioner’s returns. To the extent that petitioner’s expenditures plus deposits exceeded funds available from identified sources, she presumed that petitioner had additional unreported income from farming. Petitioner’s uncorroborated account of his withdrawals of his father’s inheritance from the ammunition box did not persuade her otherwise. The adjustments set forth in the notice of deficiency followed Duffy’s computations. Before trial respondent revised the revenue agent’s computations on the basis of additional information obtained fromPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011