Linda Ruth Palmer - Page 5




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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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