- 9 - tax basis of the residence by casualty losses sustained and claimed in prior years. During respondent’s audit, when petitioner was asked if he had made any purchase with cash in excess of $10,000, petitioner incorrectly stated that he had not done so. On August 17, 1988, respondent’s representative requested petitioner to provide copies of all bank statements for 1985 through 1988 relating to Cal Ben and to petitioner. In response to that request, respondent’s representative was provided documents pertaining only to the two bank accounts at Bay Bank of Commerce. Respondent's representative was not informed by petitioner of the Lloyds/Sanwa account. When he discovered deposits into the Lloyds/Sanwa account, respondent's representative requested of petitioner records pertaining to that account, but petitioner refused to provide any further information. At the conclusion of respondent’s audit, respondent determined against petitioners the income tax deficiencies, the fraud, and the negligence additions to tax set forth above, and respondent determined that the fraud related only to unreported sales of Cal Ben and that negligence related to all other adjustments. In determining the income tax deficiencies, respondent allowed as business expense deductions nearly all of the costs and expenses that were recorded in Cal Ben’s books and recordsPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011