Morton Zuckerman - Page 8

                                        - 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.                                


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