- 8 - Further, the regularly maintained business records of Behring Diagnostics, the corporate successor of Syva Co., contain invoices from California Barbecue for various catering services in 1990 and 1991, as well as copies of Syva Co.’s checks in payment of these invoices. Syva Co.’s records also contain a copy of a Form 1099-MISC issued to California Barbecue for 1990 (listing petitioner’s Social Security number as the taxpayer identification number), and no Form 1099-MISC for 1991 (in which payments to California Barbecue did not exceed $600). Syva Co.’s records also contain invoices with the legend “California Barbeque” and petitioner’s address printed thereon. Further, it was Syva Co.’s policy to obtain a taxpayer identification number before making payment on an invoice. In addition, respondent has matched petitioner’s Social Security number and address to a bank account registered in his name “D.B.A. Thru The Lens, Sole Proprietor”. Numerous deposits were made to, and checks drawn on, this account during 1990 and 1991. The checks for this account were preprinted with petitioner’s address and the legend “Thru The Lens”. Accordingly, the determination of unreported income in the notice of deficiency is presumptively correct, and the unreported income alleged in respondent’s amendment to answer is not arbitrarily asserted.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 Next
Last modified: May 25, 2011