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income calculation. Mr. Keller’s conclusion was based on his
determination that: (1) Petitioners maintained inadequate
records as to their income and expenses, (2) petitioners appeared
to be living a lifestyle that did not comport with their reported
income, and (3) respondent had received the STRs as to
petitioners.
For purposes of the notice of deficiency, respondent
determined petitioners’ income using the net worth method (the
same method used by Mr. Keller). Respondent’s notice of
deficiency lists that petitioners’ net worth, increase in net
worth, total net worth, and personal living expenses were as
follows for the related years:
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Last modified: May 25, 2011