- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011