- 9 - Petitioner admitted at trial that she refused to provide respondent with any of K & A's bank statements for each of the taxable years in issue. Petitioner also refused to provide respondent with any billing statements issued by K & A to its customers during the taxable year 1994. This documentation could have permitted respondent to ascertain the correctness of the reported income. Given the absence of any documentation in the record, we find that respondent was reasonable in reconstructing petitioner's income under the source and application of funds method. Despite our conclusion that respondent was reasonable in the determination to reconstruct petitioner's income, the record indicates that petitioner's living expenses were less than the average living expenses provided in the BLS tables. The average living expenses provided in the BLS tables includes costs for shelter in the amount of $4,089.5 During the taxable year 1994, however, petitioner did not incur any rent or mortgage expense. Accordingly, we reduce petitioner's living expenses, as reflected in respondent's reconstruction, by the amount of $4,089. Consequently, we conclude that petitioner failed to report income 5 Respondent did not include any funds expended for dormitory lodging. Since the record reflects that such lodging was paid out of loans or scholarship funds, such payments would be properly excluded from a source and application of funds analysis.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
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