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Service began an examination of petitioner's 1990-93 tax years. On
the basis of this examination, the agent reconstructed petitioner's
income from his cattle-breeding operations for years 1990-93 by
combining a bank deposit analysis of the Third National Bank
account held by petitioner and his wife with an analysis of
nondeposited cash sales of cattle. The parties stipulated that the
following represents a proper calculation of the unreported gross
receipts received by petitioner from his cattle-breeding operation
during the years in issue:
1990 1991 1992 1993
Total deposits
to bank account $55,370.14 $151,571.06 $80,084.43 $110,639.83
Less: nonincome
deposits 30,527.77 56,150.95 37,417.52 71,427.61
Net income
deposits 24,842.37 95,420.11 42,666.91 39,212.22
Add: receipts
from cattle sales
not deposited 39,810.90 33,850.00 1,000.00 13,500.00
Unreported gross
receipts 64,653.27 129,270.11 43,666.91 52,712.22
Petitioner, however, maintains that a portion of each year's
"unreported gross receipts" produced from his cattle-breeding
operation represents amounts he received on behalf of others with
respect to their interests in the cattle sold. In this regard,
petitioner claims that he received the following amounts on behalf
of the Vanderhaydens and Mr. Stennett (as well as others), which
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