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accurately reported and verified.
Please send us, within the next 6 months, an
explanation of how you are correcting your
recordkeeping to meet the requirements of the law.
Notices of Deficiency
Respondent issued a notice to petitioner and Ms. Brodsky for
1991 and 1992 and a separate notice to them for 1993. In those
respective notices, respondent determined that petitioner and Ms.
Brodsky had unreported Schedule C gross receipts for 1991, 1992,
and 1993 in the respective amounts of $121,771, $348,205, and
$758,400. In order to make those determinations, respondent
reconstructed under the bank deposits method petitioner’s Sched-
ule C gross receipts for each of the years 1991, 1992, and 1993
(respondent’s bank deposits analysis). Respondent used that
indirect method of reconstructing those gross receipts because
petitioner and Ms. Brodsky had not maintained adequate books and
records for those years.
Each of the notices included schedules in which respondent
listed for each of the years at issue respondent’s position
regarding the sources of the deposits “Related to Schedule C
Income” into petitioner’s accounts during each such year and the
total amount of such deposits during each such year from each
such source. In reconstructing the income of petitioner and Ms.
Brodsky for the years at issue, respondent added to the results
produced by respondent’s bank deposits analysis certain addi-
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