- 8 - For the years 1995 and 1996, Mr. Yang personally prepared petitioners’ Federal income tax returns. On their 1995 return, petitioners reported total gross income of $1,903 ($1,716 interest and $187 capital gain). On their 1996 return, petitioners reported total gross income of $3,660 ($2,872 interest and $788 capital gain). The returns listed Mr. Yang’s occupation as unemployed, reported that petitioners had no interest in a foreign bank account, and reported no income from Torrance Consulting, Summit Consulting, or Mr. Yang’s interest in the family operated factory in Taiwan. On March 19, 1999, respondent issued a notice of deficiency for the years 1995 and 1996. OPINION Respondent’s notice of deficiency determined unreported income based on the bank deposits method of reconstructing income. Respondent’s determination is entitled to the presumption of correctness, and petitioners bear the burden of proving that such determination is incorrect. See Rule 142(a); Tokarski v. Commissioner, 87 T.C. 74, 76-77 (1986); Estate of Mason v. Commissioner, 64 T.C. 651, 657 (1975), affd. 566 F.2d 2 (6th Cir. 1977). Petitioners claim that the amounts deposited to their bank accounts were nontaxable gifts from Mr. Yang’s father.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011