Lucila Novoa - Page 11

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               In January 1993, petitioner's friend, Vilma Reye, lent her             
          $500.  In April 1993, Petitioner repaid the loan in its entirety.           

                                       OPINION                                        
          A.   Respondent's Reconstruction of Income                                  
               Section 6001 requires all taxpayers to maintain adequate               
          books and records of taxable income.  In the absence of adequate            
          books and records, the Commissioner is authorized to reconstruct            
          the taxpayer's income by any reasonable method that clearly                 
          reflects the taxpayer's income.  Sec. 446(b); Holland v. United             

               7(...continued)                                                        
                    Initial unreported income in the             $26,987              
                    statutory notice                                                  
               Cash expenditure increase for additional          +14,484              
                    Schedule C deductions allowed                                     
                    Decrease in bank deposits for interbank      -22,500              
                    transfers                                                         
                    Increase in cash expenditures resulting      +22,500              
                    from decrease in total checks disbursed                           
                    Decrease in cash expenditures resulting       -1,975              
                    from decrease in total expenditures                               
                    relating to overstatement of payment at                           
                    closing of the house in the statutory                             
                    notice                                                            
                    Decrease in cash expenditures relating       -6,166               
                    to Schedule E expenses disallowed                                 
                    Adjustment for $3,841 error in               -7,682               
                    Ms. Dickerson's report.  Instead of being                         
                    a cash outlay, such amount represents an                          
                    excess of total checks disbursed over total                       
                    expenditures                                                      
                    Revised unreported income                    25,648               



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