Ghalardi Income Tax Education Foundation - Page 11

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             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      19,672.92              






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