- 5 - During the audit process, Agent Koczergo calculated that $552,594.68 in deposits was made to petitioners' bank accounts, and from that amount she made the following adjustments/reductions: $122,776.85 for transfers between accounts; $82,387 for the gross receipts reported by petitioners; $27 for interest and $18 for dividends reported by petitioners; $12,535 for disability payments received by petitioners; and $875 for sales tax paid. After subtracting the total of those amounts from the $552,594.68 in deposits, Agent Koczergo calculated and proposed net bank deposits and unreported gross receipts of $333,975.83. Following the audit and during the pretrial portion of this case, Agent Koczergo was informed of additional nontaxable transfers that would increase the total from $122,776.85 to $131,901.37 and correspondingly reduce the net bank deposits and proposed unreported income from $333,975.83 to $324,851.31. Respondent determined unreported gross receipts of $333,976 in the notice of deficiency and now concedes that the correct amount, in accord with Agent Koczergo's revised calculations, should be $324,851. With respect to the cost of goods sold reported by petitioners, Agent Koczergo was unable to reconcile that amount to the records (vendor ledger sheets and canceled checks) provided by petitioners. Accordingly, she reconstructedPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011