Reliable Credit Association, Inc. - Page 3

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          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 and               







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