- 11 - determined that Ghalardi had received unreported income during 1993 in the amount of $15,585, the excess of the sum of the total deposits to Ghalardi's bank accounts and cash received, $38,430, over the gross receipts reported on Ghalardi's Schedule C, $22,845. Second, respondent determined that Ghalardi is entitled to none of the expenses claimed as deductions on its Schedule C for 1993 because Ghalardi did not establish that it was engaged in a trade or business, that the amounts were paid, or that they constituted allowable deductions. Finally, respondent determined Ghalardi's liability for the accuracy-related penalty imposed under section 6662(a) for negligence or disregard of rules or regulations or, in the alternative, for substantial understatement of income tax. Respondent made seven adjustments in the notice of deficiency issued to Mr. Webber. First, respondent increased Mr. Webber's taxable income for 1992 and 1993 in the amount by which the total deposits to Mr. Webber's bank accounts and cash received exceed the gross receipts reported on Mr. Webber's Schedules C as follows: 1992 1993 Total deposits and cash received $62,140.06 $47,711.92 Less gross receipts reported 31,546.00 28,039.00 Unreported income 30,594.06 19,672.92Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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