- 7 - 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 nothingPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
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