Ramon and Irma Ortiz - Page 8

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          1987 Puerto Rican tax return and a certificate of nonfiling for             
          petitioners for 1988 through 1994.  Petitioners do not recall               
          having filed tax returns in Puerto Rico after 1988.                         
               Petitioners reported adjusted gross income of $32,041 on               
          their 1990 Federal income tax return.  That return did not report           
          a capital loss, and petitioners did not make an election to carry           
          forward a net operating loss.                                               
          Respondent's Determination of Unreported Income                             
               In the audit of the income tax returns, the revenue agent              
          deemed petitioners' records to be inadequate.  Consequently, he             
          computed their taxable income for 1991 and 1992 by using a bank             
          deposits analysis.  He took the total deposits from the personal            
          and business bank accounts and combined them.  He then subtracted           
          amounts to account for interbank transfers, gifts, loans,                   
          redeposits, and other nontaxable items to determine unreported              
          income.  The revenue agent who performed the bank deposits                  
          analysis requested an extension of time to complete it but the              
          extension was not granted by petitioners.  At trial the agent               
          stated that he thought the determination was, in his best                   
          estimate, correct.                                                          
               In the notice of deficiency, respondent determined                     
          unreported income by the bank deposit analysis as follows:                  
          Bank Deposit Analysis                        1991      1992                 
          Deposits to Business Account--Osceola   $1,536,251  $3,598,451              
          Deposits to Personal Account--Barnett         67,066      52,403            





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