Simco Automotive Pump Co., Inc. - Page 11




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               In the notice of deficiency with respect to Simco,                     
          respondent determined inter alia that Simco had unreported income           
          in the amounts of $8,521 for its taxable year ended June 30,                
          1990, and $860 for its taxable year ended June 30, 1991.  The               
          amounts determined to be unreported income in these years                   
          represent the difference between the proceeds from the scrap                
          metal sales to Dix Scrap and the amounts reported as additional             
          income on Simco’s amended returns, as follows:                              
               Fiscal  Scrap metal  Amount reported    Unreported                     
               year      proceeds on amended return    income determined              
               6/30/90   $62,699       $54,178         $8,521                         
               6/30/91   80,589        179,728         860                            
               1Respondent treated the amount reported on the amended                 
               return as being $79,729.                                               
          In addition, respondent determined that Simco is not entitled to            
          the claimed offsetting deductions for “increase in salaries” in             
          the amounts of $54,178 and $79,728 for its 1990 and 1991 taxable            
          years, respectively.                                                        
               In the notice of deficiency with respect to John, respondent           
          determined inter alia that John had unreported income in the                
          amounts of $9,905 for tax year 1989 and $34,731 for tax year                
          1991.  The amounts determined to be unreported income in these              
          years represent the difference between the scrap metal sales                
          proceeds retained by John and the amounts he reported as                    
          additional income on his amended returns, as follows:                       






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