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After concessions,3 the following issues remain in dispute:
3 The parties have settled some of the adjustments as
follows:
1. Respondent concedes that the adjustments for
"Unexplained Deposits" 1988 and 1989 should be reduced by $13,837
and $6,238, respectively.
2. The Takaos agree that $10,108 of the $81,933 adjustment
for "Unexplained Deposits" for 1991 attributable to deposits to
the Industrial Bank of Japan and to the Chou Trust and Banking
Co. is taxable income not reported on their 1991 return.
3. Respondent concedes the adjustments for "Dividend
Income" should be decreased as follows:
1988 $109,849
1989 85,888
1990 106,664
1991 84,855
The Takaos concede the remaining amounts under this adjustment,
which are $1,000 for each year in issue.
4. Respondent concedes the adjustments entitled "Purchase
Expenses" for all the years in issue.
5. Respondent and the Takaos agree that adjustments for
"Advertising Expenses--Schedule C" for 1990 and 1991 are settled
by reducing the amounts by $2,531 and $1,274, respectively.
6. Respondent and the Takaos agree that adjustments for
"Car and Truck Expenses--Schedule C" are settled by reducing the
amounts as follows:
1988 $3,523
1989 4,000
1990 4,010
1991 3,936
In the stipulation of settled issues the years are shown as 1988,
1990, 1991, and 1992. We assume the years should have been shown
as above inasmuch as 1992 is not involved in the instant case.
Should our assumption be erroneous, the parties should calculate
the adjustments for "Car and Truck Expenses--Schedule C" in the
Rule 155 computations in the manner necessary to comport with the
agreement of the parties.
7. Respondent concedes adjustments for "Depreciation
Expenses--Schedule C" for all years in issue.
8. Respondent concedes adjustment entitled "Repairs Expense
--Schedule C" for 1988.
9. Respondent concedes adjustment for "Supplies Expenses"--
Schedule C" for all years in issue.
10. Respondent and the Takaos agree the adjustments for
"Travel Expenses--Schedule C" are settled by reducing the amounts
as follows:
1988 $2,073
(continued...)
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