Warren R. Ketler - Page 5




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          of documents at the proper address.  Petitioner did not respond             
          to this motion.                                                             
               Shortly before the trial opened, the Great Western Bank,               
          pursuant to a summons, provided respondent with bank records.               
          The records reveal that, during the years in issue, petitioner              
          maintained a Great Western Bank account in the name of "Warren R.           
          Ketler, D.B.A. Thru The Lens".  The signature card for the                  
          account used petitioner's Social Security number and address.               
          Thru The Lens is a photography business.  Bank statements of this           
          account, No. 308-8083971, reveal total deposits of $8,563 for               
          petitioner's taxable year 1990 and $23,691 for 1991.                        
               The summoned records also reveal that petitioner had a                 
          separate individual account at Great Western Bank, No. 308-                 
          8064948, maintained under his own Social Security number and                
          mailing address.  Statements of this account reveal total                   
          deposits of $80,609 for 1990 and $39,467 for 1991.  Petitioner              
          commingled the income and expenses of Thru The Lens between                 
          account Nos. 308-8083971 and 308-8064948.                                   
               Respondent then reconstructed petitioner's income on the               
          basis of these bank records.  Respondent determined that some of            
          the deposits into the Thru The Lens account were not accessions             
          to income but rather transfers from petitioner's individual                 
          account.  These transfers totaled $2,900 in 1990 and $1,000 in              
          1991.  Respondent further determined that some expenditures from            
          the Thru The Lens account were deductible business expenditures;            
          these totaled $4,499 for 1990 and $6,168 for 1991.                          

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