Philip L. Firetag - Page 6




                                        - 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