Raymond F. Kling and Barbara K. Kling - Page 16




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               The following additional amounts were paid from the National           
          City Bank account in 1991:                                                  
                         Payee                      Amount                            
                    Bob Kelly                     $164.00                             
                    Jim Wilson                    200.00                              
                    First Card                        200.00                          
                    Manufacturers Hanover         221.00                              
                    Evelyn Johanson               1,614.00                            
                    Wholesale Club                3,000.00                            
                    Sam's Club                    1,874.15                            
                    Cash                     $1,600.00                                
              During 1991, miscellaneous bank charges and returned check             
          fees of $269.65 were debited/charged against the National City              
          Bank account.                                                               
          c.  IRS Determination for 1991                                              
               The internal revenue agent determined Raymond's gross income           
          from the sale of sports memorabilia and supplies for 1991 as                
          follows:                                                                    
                    Ameritrust deposits                $404,748                       
                    Less misc. expenses                (5,763)                        
                    National City Bank deposits        59,199                         
                    Less misc. expenses                 (2,600)                       
                    Total                              455,584                        
               The agent further determined that petitioners' 1991 income             
          should be increased by $91,749 computed as follows:                         
                   Gross receipts                     $455,584                       
                    Purchases                          (353,234)                      
                    Rent                               (6,000)                        
                    Self-employment tax adjustment      (4,601)                       
                    Total                              91,749                         









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