- 3 - 1991 and 1992, petitioner was liable for deficiencies in the respective amounts of $1,432,427 and $1,057,707, and accuracy- related penalties under section 6662(a) in the respective amounts of $286,485 and $211,541. Essentially, respondent's determinations were based on two contentions: (1) Petitioner's method of accounting did not clearly reflect income, and, as a result, various items of interest and discount income were understated, and (2) petitioner failed to substantiate deductions for bad debts, rental expenses, and depreciation. With regard to the first contention, respondent determined that petitioner's books and records were inadequate to establish the amount of petitioner's gross income. Petitioner timely filed a petition with this Court. Subsequently, petitioner hired Milton D. Mittelstedt (Mittelstedt), a certified public accountant with Deloitte & Touche LLP, to assist in the litigation. Mittelstedt apparently did not attempt to reconcile petitioner's income from its accounting records. Rather he prepared net worth analyses. A net worth analysis is a reconstruction of a taxpayer's taxable income based on changes of net worth from the beginning to the end of a taxable period. These analyses became the basis of a settlement that was reached between petitioner and respondent's appeals officer. For services rendered between June 1995 andPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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