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(t) Attached as Exhibits 1A and 1B to the Notice
of Deficiency (which is itself attached hereto as Exhibit A)
is a bank deposits analysis statement of income
reconstruction for the petitioner's 1982 through 1984
taxable years. Such analysis is incorporated herein in its
entirety by reference. The petitioner did in fact make all
deposits to bank accounts as are reflected on those
exhibits.
(u) The petitioner's understatement of gross
receipts as determined by the bank deposits analysis method
of income reconstruction is in the amount of $95,445 for
1982, $138,160 for 1983 and $103,125 for [the] 1984.
(v) During 1982, 1983, and 1984, neither the
petitioner nor Wayne E. Palmer received any gifts,
inheritances, legacies or other devises.
(w) At the beginning of the 1982 taxable year and
at all times during 1982, 1983, and 1984, neither the
petitioner nor Wayne E. Palmer received any non-taxable or
excludable income, receipts, cash, or other assets other
than as reflected in the bank deposits analysis attached
hereto and incorporated herein by reference.
(x) The petitioner realized gross receipts from
her business during 1982 in the amount of $95,445 which she
fraudulently omitted from her 1982 joint federal income tax
return with the intent to evade income tax.
(y) The petitioner realized gross receipts from
her business during 1983 in the amount of $138,160 which she
fraudulently omitted from her joint 1983 federal income tax
return with the intent to evade income tax.
(z) The petitioner realized gross receipts from
her business during 1984 in the amount of $103,125 which she
fraudulently omitted from her joint 1984 federal income tax
return with the intent to evade income tax.
(aa) In addition to the unreported gross receipts
from her business which the respondent was forced to
determine through use of the bank deposits analysis, the
petitioner received interest income during 1982, 1983, and
1984 in the respective amounts of $7,541, $6,619 and $610.
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