- 6 - 1988 1989 1990 Source Cash on hand $12,000 Insurance proceeds $5,000 Depreciation 1,819 $11,806 9,099 Gross receipts 10,500 8,767 Sch. E income 30,000 Total sources $13,819 $22,306 $52,866 Application Sch. C expenses $35,104 $15,803 Net loss, Sch. C $6,319 Purchase motel 50,000 Personal living expense 12,600 12,600 12,600 Purchase truck 21,556 Purchase truck 6,000 Equity motel 5,431 6,457 Marijuana 56,000 92,000 Gift to brother 15,000 Legal fees 5,000 Sch. E expenses 11,922 Cash payment motel 10,050 Total applications $68,919 $136,691 $168,832 Excess of applications over sources 55,100 114,385 115,966 Respondent determined the deficiencies at issue in this case based on Roberts' analysis. C. Trial Petitioner did not appear at trial or request a continuance, and no one appeared on his behalf. At trial, respondent conceded that the $92,000 of marijuana seized by the DEA in 1990 from the second vehicle should not be counted as an application of petitioner's funds.2 2 Respondent now contends that for 1990, petitioner is liable for a deficiency of $7,851 and a penalty for fraud under sec. 6663 of $5,888.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011