- 19 - Respondent issued a notice of deficiency (notice) to pe- titioners with respect to their taxable years 1992, 1993, and 1994. In the notice, respondent determined, inter alia, that petitioners had unreported income for 1992, 1993, and 1994 in the amounts of $60,034, $53,094, and $57,891, respectively, the likely source of which was Paul & Joe, Inc. In making those determinations, respondent relied on an analysis under the bank deposits method of petitioners' bank deposits during the years at issue, which showed that petitioners had unexplained bank de- posits during those years. Respondent further determined in the notice that the cost of goods sold reported by Paul & Joe, Inc., for 1993 and 1994 was understated in the amounts of $16,515 and $19,637, respectively, because Mr. Mifsud made purchases for Paul & Joe, Inc., during those years, which were not reimbursed by that company.3 In the notice, respondent determined that pe- titioners had deficiencies in tax (and underpayments) for 1992, 1993, and 1994 in the amounts of $18,087, $15,653, and $17,073, respectively. Respondent further determined in the notice that petitioners are liable for each of the years at issue for the fraud penalty under section 6663 on the entire amount of each such underpayment. 3 The notice indicates that no adjustment was made to cost of goods sold for 1992 because no information was available for that year.Page: Previous 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 Next
Last modified: May 25, 2011