- 11 -11 The 1990 return reported gross income before adjustments of $5,791. Petitioners never filed amended returns. Mrs. Taylor knew that petitioners had not filed tax returns for the years in issue. In January 1992, when she signed the delinquent returns, Mrs. Taylor knew about the existence of petitioner's check-kiting scheme. She also knew about the grocery/convenience store business but never questioned why income from that business was not reported on the delinquent returns. Notice of Deficiency In the notice of deficiency, respondent determined unreported net income from the grocery/convenience store business through an analysis of the bank deposits, ledger notations, Department of Treasury statistics, and industry guidelines. The unreported net income was determined to be $72,919 for 1988, $102,370 for 1989, and $87,877 for 1990. Respondent further determined petitioners had unreported income in 1988 from petitioner's check-kiting scheme in the amount of $300,698.5 Respondent determined that petitioners were liable for the fraud addition to tax for 1988, or in the event respondent's fraud determination is not sustained, an addition to tax for negligence or disregard of rules or regulations, an addition to tax for substantial understatement of tax, and an addition to tax for failure to timely file a Federal tax return. For 1989 and 1990, 5 See supra note 2.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011