- 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 the
Page: Previous 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 NextLast modified: May 25, 2011