- 10 - For petitioner's 1992 taxable year, respondent determined that petitioner had $146,000 of unreported tax preparation income. A PIL for petitioner's 1992 taxable year was unavailable. However, the record indicates that petitioner prepared at least 3,000 returns in 1992. Agent Donovan testified that $146,000 was a result of increasing his figure of $122,000 of unreported tax preparation income from 1991 by 20 percent, yielding $146,600, rounded down to $146,000. Agent Donovan derived the factor of 20 percent by using the 31 percent increase in the comparative 3 days of receipts for the month of February in 1990, 1991, and 1992 and reducing the percentage to 20 percent to account for the fact that petitioner's tax preparation business ceased on April 10, 1992. Under these circumstances, we conclude that respondent's method of reconstructing petitioner's 1990, 1991, and 1992 tax return preparation income is reasonable. Therefore, respondent's determination that petitioner had unreported tax preparation income of $83,000, $122,000, and $146,000 for 1990, 1991, and 1992, respectively, is sustained. Respondent also determined that petitioner had unreported notary income of $4,000, $6,000, and $7,000 in 1990, 1991, and 1992, respectively. Petitioner's notary journal, which covers the period from December 22, 1989 to August 9, 1990, includes thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011