Richard and Rebecca Adair - Page 8




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               For 1993, 1994, and 1995, IRS Publication 1136, Statistics             
          of Income Bulletin, reflected the following average net profit              
          margins for roofing contractors:                                            

          Average                                                                     
                                        Net Profit                                    
            Year        Margins                                                       
          1993                               20%                                      
          1994                          25%                                           
          1995                          18%                                           

               As indicated, respondent’s tax deficiencies determined                 
          against petitioners are based on deposits to the checking account           
          with no allowance for labor and material costs which obviously              
          were incurred in the roofing business.  We conclude that for each           
          year it is appropriate to apply to the checking account deposits            
          that are specifically identifiable as gross receipts of the                 
          roofing business (namely, those deposits that represent the                 
          checks received from Roof Technologies and Vaughn Roofing) the              
          average net profit margin established by respondent for roofing             
          contractors and to allow estimated business expense deductions              
          for the business expenses so calculated.                                    
               Petitioners have presented no evidence as to how the income            
          from the roofing business should be divided between them and                
          Delwin Houser.                                                              
               At trial, Rebecca Adair was asked several times her opinion            
          on how income relating to the roofing business and to the                   
          checking account deposits should be divided between herself, her            





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