- 14 - not give this analysis to Clement. Among the records petitioner used to reconstruct Sand Hill's income were monthly statements from its Bank of America account. On October 31, 1995, Clement met with petitioner and his accountant to review records for Sand Hill's expenses and petitioners' deductions disallowed in the notice of deficiency. For recording Sand Hill's expenses, petitioner used a spiral- bound notebook with accounting paper. Using this notebook, petitioner verified each and every expense paid by Sand Hill for which deductions were claimed by petitioners on their Schedules C. Clement determined that petitioner kept the notebook in the ordinary course of business during 1990 and that it was an adequate record for petitioners' business. Petitioner, however, did not present records of Sand Hill's income to Clement, so the agent used petitioners' bank records to analyze deposits and transfers to reconstruct Sand Hill's income. In their petition, the Paus denied that they had received income of $840,000 that they did not report on their 1990 return. Respondent's answer asserted that petitioners failed to report additional Schedule C income of $616,789, including the $150,000 consultation fee received by Susanna. Respondent further asserted that the underpayment of petitioners' tax for 1990 attributable to their unreported income was due to fraud, and that any deficiency stemming from that income is subject to thePage: Previous 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 Next
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