Lucila Novoa - Page 8

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          that petitioner had unreported income in the amount of $26,987.             
          On November 26, 1996, respondent issued a statutory notice of               
          deficiency.  Ms. Dickerson's report reconstructing petitioner's             
          income was attached.  The notice of deficiency listed the                   
          following adjustments to petitioner's income:  (1) $44,471                  
          increase in Schedule C net profit resulting from the $26,987 of             
          unreported income determined by Ms. Dickerson's reconstruction              
          of petitioner's income and the disallowance for lack of                     
          substantiation of $17,484 in deductions for Schedule C business             
          expenses; (2) $2,350 increase of "other income", representing               
          petitioner's gain on the truck sale; and (3) $6,166 increase in             
          rent income, resulting from petitioner's $2,800 computational               
          error plus $3,366 of expenses disallowed for lack of                        
          substantiation.                                                             
               Following pretrial discovery, respondent made several                  
          adjustments to Ms. Dickerson's reconstruction of petitioner's               
          income and recomputed petitioner's unreported income.  Respondent           
          determined that petitioner had unreported income of $25,648,                
          $1,339 less than the unreported income originally determined by             
          Ms. Dickerson and set forth in the statutory notice of                      
          deficiency.                                                                 
               The following table sets forth Ms. Dickerson's initial                 
          reconstruction of petitioner's unreported Schedule C income and             
          respondent's reconstruction and revised computation:                        





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