- 8 - deficiency for 1989, Baker reduced from $16,511 to $9,845 the amount of personal expenditures contained in the 1989 criminal net worth computation3 and disallowed the $6,000 personal exemption that had been allowed in the criminal net worth computation. The net result of these two changes was a decrease in the amount of petitioner husband’s unreported income. In drafting the notice of deficiency for 1990, Baker increased by $12,421 the offset allowed for income reported on the return, but omitted the $27,412 of “deductions”–-comprising $12,356 for petitioner wife’s wages, $6,856 for petitioners’ settlement of their injury claims from the automobile accident, and $8,200 for personal exemptions–-that had been allowed in the criminal net worth computation, resulting in an increase in the amount of petitioner husband’s unreported income.4 3 The record does not reveal the basis upon which Baker determined this lesser amount of personal expenditures. 4 The net worth analyses included in the 1989 and 1990 statutory notices of deficiency were as follows: Particulars 12/31/89 Understatement of income $14,690 Total assets $7,445 Less: Total liabilities (2,600) Net worth 4,845 Less: Prior years net worth ( -0-) Increases in net worth 4,845 Plus: Expenditures 9,845 Understatement of income 14,690 (Increase in net worth ====== plus expenditures) (continued...)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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