17 9012 9112 9212 Per return $1419282 $4147691 $3306595 Per audit 2934384 4145992 3320229 Adjustment $15051021 $ (1699) $ 13634 1 The correct adjustment for 1990 is $1,515,102. Respondent does not explain this discrepancy. The copy that respondent sent to petitioner did not disclose that it differed from the original version. The change makes the letter appear more likely to be the letter to which the notice of deficiency refers because the notice of deficiency states that the letter furnished to the taxpayer was based on an examination of Eagle's 1990, 1991, and 1992 years. The Court held a hearing on October 29, 1996, relating to petitioner's allegation that respondent had provided an altered document to be included in the stipulation. Respondent's agent testified that she had not added the 1992 column to the report and did not know who did. The Court held a second hearing on October 30, 1996, based on petitioner's allegation that the revenue agent's testimony was false. At the second hearing, respondent's agent testified that she had added the 1992 column. II. OPINION A. Tax Treatment of Eagle's Customer Deposits 1. Petitioner's Contentions Petitioner contends that Eagle need not report all of its customer deposits in the year received. Petitioner contends thatPage: Previous 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 Next
Last modified: May 25, 2011