Ronald D. and Shirley A. Blush - Page 4




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          From Business, reporting $35,344 and $20,984 in gross receipts              
          for 1993 and 1994, respectively.  Upon examination of                       
          petitioners' tax returns, respondent's revenue agent concluded              
          that, to some extent, petitioner's business was conducted in                
          cash.  Petitioners did not present adequate books or records to             
          respondent's revenue agent pertaining to the income generated by            
          petitioner's business.  The revenue agent performed a bank                  
          deposits analysis of the tax years in issue to determine                    
          petitioners' income.  A summary of the revenue agent's bank                 
          deposits analysis for 1993 and 1994 reflects the following:                 
                                        1993                                          
               Deposits to bank accounts               $93,452                        
               Less deposits from known sources         77,315                        
               Total unexplained deposits              116,137                        
                                        1994                                          
               Deposits to bank accounts               $72,808                        
               Less deposits from known sources         49,190                        
               Total unexplained deposits              123,618                        
               1  As previously indicated, respondent has made concessions            
          reducing the amounts of unexplained deposits.                               
               During the initial interview with petitioners'                         
          representative, the revenue agent inquired as to the amount of              
          cash petitioners had on hand during the years in question.                  
          Petitioners' representative did not provide an answer.  The                 
          revenue agent prepared an information document request that again           
          inquired as to the amount of cash petitioners had on hand.                  
          Petitioners responded that they did not know how much cash they             





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