-8- 1989 1990 1991 1992 Gross receipts $336,545 $450,252 $476,785 $234,677 Allowed business 280,733 264,280 271,515 103,262 expenses Unreported net 55,812 185,972 205,270 131,415 business income Allowed expenses 83.4% 58.7% 56.9% 44.0% as a percentage of gross receipts Respondent's Reconstruction of Petitioner's Income for 1993-94 Respondent did not use the "specific items" method to reconstruct petitioner's income for 1993 and 1994. Instead, respondent determined petitioner's income by reference to Bureau of Labor Statistics average cost-of-living survey information. Using this information, respondent determined that petitioner had a cost of living--and therefore must have had unreported net business income--of $34,533 and $35,638, in 1993 and 1994 respectively. After allowing petitioner one personal exemption, the standard deduction, and a deduction for self-employment tax, respondent determined that petitioner's taxable income was $26,043 and $26,870 in 1993 and 1994, respectively. OPINION I. Is Petitioner Entitled to Additional Deductions for 1989-92? Prior to trial, the parties stipulated that petitioner's gross receipts for 1989-92 were equal to the amounts determined by respondent. The parties also stipulated that petitioner's unreported net business income for 1989-92 was equal to thePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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