Stephen H. Rifkin & Pamela T. Rifkin - Page 6

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          petitioners' cost of goods sold by adding the following amounts:            
          $196,398 shown in petitioners' vendor ledger sheets; $67,321                
          shown on canceled checks that did not appear to be a duplication            
          of those shown on the vendor ledger sheets; $373 based on oral              
          representations received by Agent Koczergo; $22,939 shown on                
          check stubs for December (no canceled checks were available for             
          December) that did not appear to be a duplication of those shown            
          on the vendor ledger sheets; and $3,053 shown on check stubs, for           
          months other than December, that did not appear to be a                     
          duplication of those shown on the vendor ledger sheets.  In this            
          manner, Agent Koczergo computed a total cost of goods sold of               
          $290,084 for 1993.  Respondent's notice of deficiency contained             
          the determination that the $32,453 petitioners reported as cost             
          of goods sold should be increased by $257,631 to arrive at the              
          $290,084 calculated by Agent Koczergo.                                      
               Petitioners reported on their 1993 income tax return a                 
          $65,329 opening and a $32,876 ending inventory and no purchases,            
          costs of materials, labor, or supplies.  After subtracting the              
          reported ending from the opening inventory, petitioners reflected           
          a $32,453 cost of goods sold.  Agent Koczergo did not observe any           
          inventory on hand during audit-related trips to petitioners'                
          home/business location, and she did not use an inventory figure             
          in arriving at cost of goods sold.                                          








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