Karan M. Hintze - Page 6




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               During the years at issue, petitioner maintained two                   
          accounts at Seafirst Bank.  Account No. 90708355 consisted of a             
          checking account (checking account 355) and a savings account               
          (savings account 355).  Similarly, account No. 907163317                    
          consisted of a checking account (checking account 317) and a                
          savings account (savings account 317).  The manner in which                 
          respondent used these accounts to reconstruct petitioner’s gross            
          income is set out below.                                                    
               1.   Adjustments for 1992 Tax Year                                     
               Respondent determined that the deposits to petitioner’s                
          savings accounts represented nontaxable income.  Accordingly, in            
          reconstructing petitioner’s gross income for tax year 1992,                 
          respondent considered only the deposits to checking account 355             
          and checking account 317.  The deposits to checking account 355             
          during 1992 totaled $39,091.52, and the deposits to checking                
          account 317 totaled $2,800.64.3  From the gross receipts of                 
          $41,892.16, respondent subtracted $8,775.54 on account of                   
          deposits representing transfers from petitioner’s other bank                
          accounts.  Respondent subtracted an additional $2,502 for                   
          deposits representing nontaxable gifts from petitioner’s parents.           
          With total subtractions from gross receipts of $11,277.54,                  
          respondent determined that petitioner recognized gross income of            


               3  The totals of the deposits to checking accounts 355 and             
          317 are those determined by respondent.  Petitioner does not                
          contest these figures; instead, she uses them as the starting               
          point for her own gross income analysis.                                    




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