Karen Ann Keegan - Page 9

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                  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.                                                                                 




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