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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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