Chung Ui Kim and Ok Hui Kim - Page 4




                                         - 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.             









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