Gregory H. and Elizabeth A. Price - Page 6




                                        - 6 -                                         

               For 1989 and 1990,1 total unexplained deposits, as                     
          determined by respondent, made into the bank accounts the                   
          partnership maintained for Stores 4 and 5 consist of the                    
          following amounts:                                                          

                         Respondent's Determination of                                
                          Partnership Unexplained Bank Deposits                       
                          1989            1990          1991                          
                    $146,609        $266,352           0                              

               For 1990, unexplained deposits, as determined by respondent,           
          made into the bank account petitioner maintained for Store 6                
          consist of $117,514.                                                        
               Where a taxpayer fails to maintain adequate books and                  
          records relating to taxable income, respondent may reconstruct a            
          taxpayer's income by any reasonable method.  See sec. 446(b);               
          Edwards v. Commissioner, 680 F.2d 1268, 1270-1271 (9th Cir.                 
          1982), affg. per curiam an Order of this Court; Parks v.                    
          Commissioner, 94 T.C. 654, 658 (1990); United Dressed Beef Co. v.           
          Commissioner, 23 T.C. 879, 885 (1955).                                      
               The bank deposits method for computing income is approved by           
          the courts.  See United States v. Soulard, 730 F.2d 1292, 1296              


          1    For 1991, total deposits made into the partnership Store 4             
          and Store 5 bank accounts were consistent with the total funds              
          from video rentals reported on the partnership’s 1991 information           
          Federal income tax return.  Accordingly, in his bank deposits               
          analysis for the partnership for 1991, respondent made no                   
          adjustments for unexplained bank deposits.                                  





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