Thomas G. Roots - Page 4

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          on Forms 1099, Miscellaneous Income, even though he knew he                 
          received additional commissions.                                            
          1.  Rental Business                                                         
               Petitioner owned approximately eight residential rental                
          properties during each of the taxable years in issue.  All rental           
          receipts, either in cash or by check, were deposited into                   
          petitioner's account at American Commercial Bank in Ventura,                
          California (ACB account), the same account into which he                    
          deposited income from other sources including his insurance                 
          agency.  For the taxable years at issue, petitioner had the                 
          information available to him to maintain accurate records of his            
          correct rental income, but he failed to maintain accurate records           
          of the amount of rent he received.  As summarized below and                 
          stipulated by the parties, petitioner failed to report all of his           
          rental income for the years in issue:                                       
                    Amount         Rental    Percentage of Rental                     
               Reported       Income              Income Petitioner                   
          Year      on Return      Received       Failed to Report                    
          1984      $25,560        $39,680        36%                                 
          1985      20,769         40,012              48                             
          1986      21,613         48,742              56                             
          1987      32,880         64,586              49                             
               Petitioner submitted applications for loans to purchase                
          property during the years in issue in which he listed his income            
          as significantly greater than the amounts shown on his returns.             
          On petitioner's May 19, 1986, application for a loan to purchase            
          a property, petitioner included a statement that he received                





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