Joao Montoro and Neuza Paula - Page 13

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          the safe, and that the money in the safe came from savings from             
          his years of working for IBM and inheritances from his father.              
               On March 29, 1994, petitioner-husband gave Davis a revised             
          estimate of the amount of his cash which included the proceeds              
          from the sale of petitioners' assets in Brazil.                             
               Davis did a bank deposits analysis to estimate petitioners'            
          income for 1990 and 1991.  She examined petitioners' bank                   
          accounts.  She sought to exclude from her analysis sources of               
          income which she thought were nontaxable, including transfers               
          between accounts, expense reimbursements, and offsetting wire               
          transfers.  She apparently did not believe that petitioners had a           
          significant amount of money in Brazil as of December 31, 1989.              
               Petitioners deposited $136,408 in nine bank accounts in                
          1990.  They reported that they had received $23,574 of that                 
          amount as Schedule C gross receipts on their 1990 return.                   
          Respondent subtracted $23,574 and gross receipts of $4,900                  
          allocated to petitioner-wife, and determined that petitioners had           
          understated their taxable income for 1990 by $107,934.                      
               Petitioners deposited $396,905 in eight bank accounts in               
          1991, $147,426 of which they reported on their 1991 return as               
          Schedule C gross receipts.  Respondent determined that                      
          petitioners had understated their taxable income for 1991 by                
          $249,479 ($396,905 - $147,426).                                             








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