Beatrice DiPierro - Page 7




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                                       OPINION                                        
          I.  Deficiencies                                                            
               A.  Normal Tax                                                         
                    1.  Introduction                                                  
               Respondent adjusted (increased) petitioner’s gross income              
          for 1992 and 1993 on account of unexplained cash deposits and an            
          unexplained cash purchase:  $25,000 deposited to NCNB National              
          Bank, account No. 3502977933 on February 10, 1992 (the NCNB                 
          deposit), $10,000 deposited to Fortune Bank account No.                     
          002-9072131 on December 8, 1993 (the Fortune bank deposit), and             
          $11,250 expended to purchase a check at NationsBank on                      
          December 9, 1993 (the NationsBank purchase, collectively, the               
          cash transactions).  Petitioner does not dispute the fact of the            
          cash transactions.  Petitioner claims that the NCNB deposit was             
          of funds received by petitioner as gifts from her children, Gary            
          and Audrey, and, accordingly, does not represent an item of gross           
          income.  Petitioner claims that the Fortune Bank deposit and the            
          NationsBank purchase were from amounts reported by petitioner as            
          gross income for 1993 and, thus, do not represent an item of                
          unreported gross income.  Respondent relies principally on                  
          petitioner’s failure to prove her claims.                                   
                    2.  Respondent’s Examination                                      
               Petitioner argues that respondent’s examination in this case           
          was inadequate:  “The auditor in this case did little or nothing            





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