- 7 - Thereafter, petitioners administratively appealed Revenue Agent Bacino's determinations. With additional substantiation at the appeals level, respondent's Appeals Office determined that petitioners' cash expenditures during 1992 were $6,152 rather than $31,435 as determined by Revenue Agent Bacino, and that there were additional nontaxable deposits to petitioners' accounts in the amounts of $23,696 for 1991 ($13,065 for "not sufficient funds" deposits, $6,205 for "insurance loan" and $4,426 for "insurance proceeds") and $8,485 for 1992 (for "not sufficient funds" deposits). Thus, respondent's Appeals Office redetermined a total adjustment for 1991 in the amount of $108,310 and for 1992 in the amount of $133,730. Petitioners also reasserted their claim that the deposits were from additional loans, gifts, and inheritances. However, they did not provide any further substantiation for this claim, and respondent's Appeals Office did not accept it. At the appeals level, petitioners for the first time actively argued that a large portion of the deposits to their personal bank accounts constituted: (1) Corporate gross receipts previously reported on RAJ's returns, and (2) distributions with respect to petitioners' stock previously reported at the corporate level. To substantiate the claim that a portion of the deposits constituted corporate gross receipts previously reported on RAJ's returns, petitioners provided the Appeals officer with a summaryPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011