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1991. Initially, petitioner did not provide copies to his tax
preparers of the 1988 through 1991 bank statements for this
account, although he provided the 1991 statements to Mr. Hwang in
late 1992. None of the deposits into this account were reflected
on petitioner's 1988, 1989, 1990, and 1991 Federal income tax
returns. In 1991, petitioner endorsed and deposited insurance
settlement checks into his Mitsui Manufacturers Bank client trust
account. The gross amounts of these checks are as follows:
Date of Deposit Amount
5/20/91 $6,700
5/20/91 7,000
5/20/91 6,500
6/26/91 8,000
6/26/91 5,750
7/17/91 6,500
7/17/91 6,800
7/17/91 8,750
7/17/91 8,750
7/17/91 8,750
7/17/91 9,600
7/17/91 5,000
Total 88,100
Petitioner also deposited $3,000 in cash to this account on March
1, 1989. These amounts also form part of respondent's adjustment
to petitioner's Schedule C gross receipts.
Petitioner's Assets
During the years in issue, petitioner reported the following
net income from his law practice:
Year Net Schedule C Income
1988 $10,292
1989 36,211
1990 96,945
1991 65,337
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