- 8 -
available to him, and consequently he resorted to an analysis of
their bank deposits. His analysis was limited to the accounts
that he was able to identify through a search, using petitioner's
Social Security number, of interest-bearing accounts reported to
the Internal Revenue Service on Forms 1099. In computing
deposits made to each account, he excluded any funds transferred
from other accounts held by the Zuckermans. All deposits that
could not be attributed to a nontaxable source on the basis of
available information were deemed to represent taxable income.
The results of the analysis are set forth below:2
Account Gross Deposits
Bank Number (incl. transfers) Net Deposits
Fairfax Savings 50-04-11525 $600.00 - 0 -
Fairfax Savings 50-04-11517 1,000.00 $1,000.00
Fidelity 3951002546 6,478.34 6,478.34
Citibank 23408711 13,486.36 11,986.36
Citibank 23408682 27,706.78 20,256.78
Citibank 23408658 55,231.96 44,931.96
Total 84,653.44
Plus:
Self-employment income originally
reported as wages $4,084.00
Total income $88,737.44
Less:
Net W-2 wages (Mrs. Zuckerman) (16,423.19)
Self-employment earnings reported as wages (4,084.00)
Gambling winnings (Mrs. Zuckerman) (2,000.00)
Total income accounted for (22,507.19)
Unreported income 66,230.25
2After checking Dickoff's work papers against the bank
statements for the six identified accounts, we are satisfied that
the deposit amounts he computed are correct. Owing to a clerical
error, the work papers misstate the interest earned for one of
the accounts, but the discrepancy amounts to only 10 cents and
does not affect the computation of deposits.
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