- 13 - Table 2 BANK ACCOUNT ANALYSIS 9112 9212 9312 9412 Total Bank Account Deposits 84,090. [3]144,149. 120,045. 139,307. less non-taxable deposits (9,066.) (37,457.) (22,219.) (45,958.) Income-wages-Net[1] (44,149.) (46,922.)[6](54,638.) (75,164.) -Retirement T/P-H (15,094.) (15,177.) (17,756.) (23,246.) -Retirement T/P-W (3,157.) -IRA Distribution (224.) -Condo Rent (8,200.) (5,895.) (4,500.) (6,950.) -Miscellaneous (147.) (675.) (368.) (668.) -Tips (1,230.) -Sale of Stock-Net (5,978.) (2,969.) Excess Deposits per Exam 4,053. [4]30,823. 17,595. (12,679.) Additional Non-Taxable Income Per Appeals Adjustments -0- (3,396.) (7,576.) Excess deposits per Appeals [2]4,053. [5]10,629. [7]10,018. -0- 1 “Net” means net of withheld amounts shown on the Forms W-2. 2 This amount is $19 less than the 1991 $4,072 notice of deficiency adjustment for Other Unreported Income. In the absence of an explanation from respondent, we conclude that the slight preponderance of the evidence of record leans toward petitioners with respect to this $19. On opening brief, respondent concedes a $21 amount, which may include this $19. The parties are directed to resolve this matter in the computation under Rule 155. 3 This amount is $10 less than the sum of the stipulated amounts deposited into petitioners’ bank accounts. Compare supra table 1, column 1992. Respondent attributes the difference to a clerical error on respondent’s part, and “concedes the $10 difference.” That is, respondent does not ask that the 1992 $10,630 notice of deficiency adjustment for Other Unreported Income be increased to correct this error. 4 This amount is $8 more than the sum of the items in the 1992 column showing the bank account analysis that respondent made in determining the amount of the 1992 $10,630 notice of deficiency adjustment for Other Unreported Income. In the absence of an explanation from respondent, we conclude that the slight preponderance of the evidence of record leans toward petitioners with respect to this $8. 5 In arriving at the 1992 Other Unreported Income adjustment in the notice of deficiency, respondent subtracted thePage: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 Next
Last modified: May 25, 2011