- 22 -
1989 and 1990 in the amounts of $1,428 and $1,289, respectively,
and (5) the settlement was based on the assertions of both Larry
and Katherine that for the years in issue Frank and Katherine had
paid all of Larry’s expenditures in excess of his income.
3. Ronnie’s Audit and Notice of Deficiency
Agent Combs notified Ronnie and Linda of the audit of their
returns on August 15, 1991. On August 31, 1995, respondent
mailed 30-day letters to Ronnie for 1983 and 1984 and to Ronnie
and Linda for 1985 though 1990 in which respondent proposed
adjustments for those years. Respondent determined those
adjustments on the basis of a source and application of funds
analysis for each of those years. Subsequently, respondent
closed Ronnie’s audit without issuing any notice of deficiency.
4. Sylvia’s Audit and Notice of Deficiency
Agent Combs notified Sylvia of the audit of her returns on
August 15, 1991. On August 31, 1995, respondent mailed 30-day
letters to Sylvia for 1985 through 1988, and to Sylvia and Jack
for 1989 and 1990, in which respondent proposed adjustments for
12(...continued)
1989 1990
Self-employment income $38,018 $43,404
Capital gain income -0- 3,725
Loss from an S corporation -0- 2,130
Depreciation expense - Schedule C (3,969) (3,969)
Depreciation expense - Schedule E 10,517 10,517
Self-employment tax deduction -0- (2,786)
Total adjustments 44,566 53,021
Page: Previous 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 NextLast modified: May 25, 2011