- 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