- 4 - Petitioners maintained two banking accounts: A personal account in their joint names and a business banking account in the name of TBJ Collections and Chung Kim, both with the California Korea Bank. The net deposits into these two accounts for 1993, 1994, and 1995 were $1,490,039, $1,481,237, and $1,575,400, respectively.3 OPINION Issue 1. Unreported Income When respondent audited petitioners’ 1993, 1994, and 1995 income tax returns in 1996, petitioners failed to provide any accounting records from which a determination could be made of TBJ’s gross receipts. Respondent therefore performed a bank deposits analysis, under which he determined that petitioners had made deposits in excess of the reported gross receipts as follows: Year Amount 1993 1$791,408 1994 735,207 1995 542,641 1Respondent concedes that this amount should be decreased to $721,408. In cases where taxpayers have not maintained business 3The net figures account for amounts attributable to transfers, sales taxes, returned checks, and paid item reversals.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 Next
Last modified: May 25, 2011