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Time to File
Year Date Filed Extended Until
1986 Jan. 18, 1994 Aug. 15, 1987
1988 June 22, 1994 Aug. 15, 1989
1989 Mar. 1, 1994 Aug. 15, 1990
1990 July 25, 1994 Aug. 15, 1991
1991 Nov. 19, 1993 Aug. 15, 1992
1992 Sept. 10, 1993 Aug. 15, 1993
For her taxable years 1986, 1990, and 1991, respondent
determined that petitioner had unreported income from her law
practice in the amounts of $6,872, $15,499, and $22,410,
respectively. Respondent conceded $7,400 of the $15,499
unreported gross receipts adjustment for 1990 and $5,080 of the
$22,410 unreported gross receipts adjustment for 1991.
Respondent’s determination of unreported income was based on a
bank deposits analysis of petitioner’s bank accounts. During the
audit examination, petitioner told respondent’s agent that
petitioner did not have any cash on hand as of the year 1986.
Petitioner maintained the following types of bank accounts:
Personal, general business (for law practice), trust (ostensibly
for client’s funds), and payroll (for law practice).
Petitioner’s total deposits to each of the four accounts were as
follows:
General
Year Personal Business Trust Payroll
1986 $17,183.51 $60,351.00 $1,043 $12,457.17
1990 3,740.30 89,175.13 100,318 8,474.44
1991 1,759.04 96,366.00 60 7,236.70
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