Martin and Barbara Schachter - Page 9

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          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 records              




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