- 6 - for bonding services were deposited into the in-house account. The moneys from the in-house account were then disbursed for four purposes: To satisfy petitioner’s liability in the event of forfeitures, to satisfy required increases in the amounts in the Charleston County Court and U.S. District Court accounts, to pay petitioner’s business expenses, and to pay petitioner a “salary”.5 Petitioner reported gross receipts from his bonding business of $80,456 in 1992 and $100,467 in 1993. However, for taxable years prior to and including 1992 and 1993, petitioner did not report as income the amounts that were deposited into the three accounts. The balances in the accounts were as follows on the dates indicated: 1/1/92 12/31/92 12/31/93 Charleston County $393,000 $537,000 $628,000 Court account U.S. District Court 55,000 30,000 30,000 account In-house account 107,909 79,636 92,699 Total 555,909 646,636 750,699 In the notice of deficiency, respondent determined that petitioner’s method of reporting bail bond fees did not clearly reflect income, and that a change in method of accounting was 5 Petitioner’s testimony regarding his salary is limited and vague. On the basis of his testimony, the amount of the salary appears to have been either a percentage of the fees he collected or a percentage of the amount in the in-house account.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011