Reliable Credit Association, Inc. - Page 11

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               Petitioner also argues that respondent should be estopped              
          from challenging the adequacy of petitioner's records because               
          respondent failed to raise the issue in a prior audit.  This                
          argument is not well taken.  It is well established that the                
          Commissioner's failure to challenge a taxpayer's treatment of an            
          item in an earlier year does not preclude an examination of the             
          correctness of the treatment of that item in a later year.                  
          Automobile Club of Michigan v. Commissioner, 353 U.S. 180, 183              
          (1957); Alfred I. duPont Testamentary Trust v. Commissioner, 66             
          T.C. 761, 765 (1976), affd. 574 F.2d 1332 (5th Cir. 1978).                  
               Lastly, petitioner claims respondent failed to employ                  
          certain "standard auditing procedures" that would have enabled              
          respondent to easily ascertain the correct amount of the                    
          deficiencies.  While, as mentioned above, petitioner does not               
          directly attack respondent's method for determining gross income            
          and deductions, petitioner contends that respondent was required            
          to make net worth analyses similar to that prepared by                      
          Mittelstedt.  Leaving aside the fact that this supposedly simple            
          endeavor cost petitioner almost $35,000 in accounting fees,                 
          petitioner has not cited, and we are not aware of, any authority            
          that requires the Commissioner to employ particular auditing                










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