Stephen H. Rifkin & Pamela T. Rifkin - Page 5

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               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 reconstructed                    






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