- 12 -
10We note that respondent’s proposed adjustment to petitioners’ 1990
taxable income is $18,865 more than what we arrive at when subtracting the
agreed upon adjustments to the bank deposit analysis from respondent’s initial
computations under the bank deposit analysis. ($500,851 - $140,101 - $379,615
= $18,865)
11We note that respondent’s proposed adjustment to petitioners’ 1991
taxable income is $86 less than what we arrive at when subtracting the agreed
upon adjustments to the bank deposit analysis from respondent’s initial
computations under the bank deposit analysis. ($236,417 + $8,997 - $245,328 =
$86)
With the exceptions noted below (see infra notes 13, 14, and
15), respondent’s final bank deposits analysis, as adjusted
pursuant to the parties’ stipulations, is supported by the facts.
On the basis of stipulated facts and evidence admitted at trial,
we find that petitioners had unreported income of $102,74813 in
1988, $320,66114 in 1989, $358,21515 in 1990, and $245,328 in
1991.
Petitioners argue that respondent’s bank deposit method is
fundamentally flawed. Admittedly, there have been a significant
13We eliminated a $5,007 item in respondent’s bank deposit
analysis for corporate expenditures on petitioners’ behalf
because the proposed adjustment was not supported by the record.
The omission has the effect of reducing petitioners’ unreported
income by $5,007.
14We eliminated an $860 item in respondent’s bank deposit
analysis for corporate expenditures on petitioners’ behalf
because the proposed adjustment was not supported by the record.
The omission has the effect of reducing petitioners’ unreported
income by $860.
15We eliminated a $2,535 item in respondent’s bank deposit
analysis for corporate expenditures on petitioners’ behalf
because the proposed adjustment was not supported by the record.
The omission has the effect of reducing petitioners’ unreported
income by $2,535. We also reduced respondent’s final computation
of unreported income by $18,865. This is the amount by which
respondent’s final unreported income determination exceeds the
amount arrived at pursuant to the stipulated adjustments to the
notice of deficiency. (See supra p.11, table note 10.)
Page: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 NextLast modified: May 25, 2011