Robert T. Schirle - Page 14

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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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