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tape on the page furnished by petitioner which stated his office
income. The Form 1099 income was then placed on line 4 of the
Schedule C for other income, while the remaining income was
included on line 1 of the 1988 Schedule C reflecting gross
receipts. The gross income stated on line 5 of the Schedule C
was $250,283.
For the preparation of the returns for 1987 and 1988,
petitioner did not give Mr. Bruno copies of any of the checks
representing income he had received from the various personal
injury attorneys. He only gave Mr. Bruno the canceled checks
representing expenses. The first year he furnished copies of
these income checks to Mr. Bruno was during the preparation of
the 1989 income tax return, after the commencement of the
Internal Revenue Service examination.
When petitioner gave Mr. Bruno the amount of income for 1987
and 1988, he did not furnish him with any bank statements or
other books or records to support his determination of income.
Petitioner had told Mr. Bruno that he determined his income from
information maintained on patient billings in his files. He did
not tell Mr. Bruno that the income amounts were only estimates.
In addition to petitioner's income from his medical
practice, he also told Mr. Bruno the amount of income petitioners
had received on each piece of their rental properties.
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