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accordingly, did not deal with Agent Harkins’ analysis of
petitioner’s financial records to verify that the schedule
provided by petitioner during the examination was correct.
Finally, petitioner did not explain the differences between the
two schedules. Accordingly, respondent’s determination was based
on verified and uncontradicted specific items of income that were
omitted from petitioner’s 1992 income, and respondent’s
determination of understatement of gross receipts for 1992 is
sustained.
Respondent also determined that petitioner understated its
gross receipts by $74,046 for the 1993 year. The statutory
notice of deficiency contains a net reduction of $59,177 to
petitioner’s claimed 1993 net operating loss, thereby reducing
the amount of any carryover to the 1994 year from the $231,441
claimed to $172,264. The $59,177 net adjustment comprises 10
items decreasing and one item increasing the 1993 net operating
loss. Our trial record and the notice of deficiency contain no
details or explanations of the $74,046 proposed understatement of
gross receipts for 1993, and the amount is apparently the result
of a general bank deposits analysis by Agent Harkins.
Unlike the specific adjustments for 1992, respondent’s
adjustment for 1993 is based on generalized bank deposits.
Petitioner addresses respondent’s determination on that item by
reconciling the total bank deposits to the items on its return in
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