- 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 Next
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