Marvin L. Barmes and Barbara J. Barmes - Page 63




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          respondent stated in the explanation of adjustments (explanation)           
          included in the notice:  “in the absence of adequate books and              
          records an indirect method was utilized to determine Gross                  
          Receipts”.  Exhibit C of the explanation further detailed the               
          method that respondent used to determine the increase in peti-              
          tioners’ 1995 gross receipts, as follows:                                   
                                                    December 31, 1994                 
           Total expense per 1994 Form 1040                                          
                  as originally filed         $1,871,671                              
            Gross profit per 1994 Form 1040                                           
                  as originally filed         2,624,759                               
             Total expense to gross profit                                            
            percentage (divide item 1 by 2)   71.31%                                  
                                                    December 31, 1995                 
           Total expense per 1995 Form 1040                                          
                  as originally filed         $1,973,107                              
             Total expense to gross profit                                            
                percentage (see above)        71.31%                                  
            Corrected gross profit (divide                                            
                      item 4 by 5)            2,766,943                               
                   Amount per return          1,876,224                               
                  Adjustment to income        890,719                                 
               In the notice, respondent also determined, inter alia, to              
          disallow the depreciation deductions of $9,400 that petitioners             
          claimed in the 1995 Schedule C.                                             
               Respondent also determined in the notice that petitioners              
          are liable for 1995 for the accuracy-related penalty under                  
          section 6662(a).                                                            
          Certain Pre-Trial Conduct of Petitioners                                    


               32(...continued)                                                       
          and not to unreported taxable income.                                       





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