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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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