Lucila Novoa - Page 7

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          Jennifer lived with petitioner in her rented apartment in West              
          New York, New Jersey, from January 1 through March 30, 1993;                
          Jennifer and petitioner then moved into the recently purchased              
          house in North Bergen, New Jersey.  Emelina continued to live in            
          petitioner's apartment through the end of 1993.  After petitioner           
          moved out of her apartment, she kept her lease on the apartment             
          and continued to make rental payments of $319 a month to the                
          landlord.  While Emelina occupied the apartment through the end             
          of 1993, she reimbursed petitioner for the monthly rental                   
          payments.                                                                   
               During 1993, Jennifer was a high school student and also               
          worked part time at the Drug Festival, Inc., in Union City,                 
          New Jersey.  Jennifer would cash her weekly paycheck, keep $5               
          for herself, and give the remainder to petitioner.  Jennifer                
          earned $6,329 of gross wages for the 1993 calendar year.  A total           
          of $1,252 was withheld from her wages for Federal, State, and               
          payroll taxes.  Petitioner used Jennifer's wages to pay household           
          expenses and buy clothing for Jennifer.                                     
          D.   Reconstruction of Income                                               
               In August 1995, Internal Revenue Service Tax Auditor Geneva            
          Dickerson (Ms. Dickerson) began an audit of petitioner's 1993               
          income tax return.  After petitioner failed to provide adequate             
          books and records of her trucking business, Ms. Dickerson                   
          reconstructed petitioner's income for the 1993 calendar year                
          using the bank deposit and cash expenditure method and determined           



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