Albert C. Johnson - Page 7

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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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