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(l) The 1994 Schedule C referred to in
subparagraph 6.(k) above reflects gross receipts or sales of
$493,956 less claimed cost of goods sold in the amount of
$333,930 for gross income of $160,026. Said Schedule C also
lists total deductions in the amount of $164,545 for a net
loss from the operation of the business in the amount of
$4,519.
(m) The petitioner listed total income tax
liability of $0 on her 1984 joint federal income tax return.
(n) The petitioner's 1982, 1983, and 1984 federal
income tax returns were prepared by the "Nevada Tax
Professionals" based upon information provided to them by
the petitioner.
(o) The petitioner did not supply the "Nevada Tax
Professionals" with access to books and records relating to
income and expenses of her business for any of the taxable
years here at issue.
(p) The petitioner failed to maintain, or submit
for examination by the respondent, any books of account
and/or records of her business relating to gross and net
receipts for each of the taxable years 1982 through 1984, as
is required by applicable provisions of the Internal Revenue
[C]ode and the regulations promulgated thereunder.
(q) Any records maintained by the petitioner for
the 1982 through 1984 taxable years are incomplete,
inadequate, fail to disclose all receipts and disbursements,
and do not properly reflect the petitioner's correct taxable
income for any of those years.
(r) The petitioner's failure to keep adequate
records regarding the income and expenses of her business
and/or her failure to turn any such records over to the
respondent constitutes indicia of the petitioner's
fraudulent intent to evade the assessment and payment of
federal income tax due following the receipt of that income.
(s) The respondent has determined the petitioner's
correct gross receipts and resultant taxable income for each
of taxable years 1982 through 1984 on the basis of the bank
deposits analysis method of income reconstruction. In
making said analysis, the respondent has utilized all
available records.
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