Lesely J. and Aljournia Moore - Page 8




                                        - 8 -                                         
               Jenkins discussed with petitioners each tax return she                 
          prepared for them.  When Jenkins asked petitioners whether all              
          of their income was accounted for, petitioners answered                     
          affirmatively.  Petitioners did not tell Jenkins about any                  
          income they received from illegal gambling activities.                      
               On their 1987, 1988, 1989, and 1990 Federal income tax                 
          returns, petitioners reported total income (or loss) in the                 
          following amounts:                                                          

                                            Total Income                              
                         Year             (Loss) Reported                             
                         1987                  $8,403                                 
                         1988                 (5,692)                                 
                         1989                  19,422                                 
                         1990                  20,975                                 
          Petitioners filed their 1987, 1988, 1989, and 1990 Federal                  
          income tax returns on November 17, 1989; October 10, 1989; April            
          19, 1991; and April 15, 1991, respectively.                                 
          Respondent’s Income Reconstruction                                          
               The Internal Revenue Service audited petitioners’ 1987,                
          1988, 1989, and 1990 Federal income tax returns.  During that               
          audit, respondent’s revenue agent concluded that petitioners’               
          records were inadequate.  Consequently, the revenue agent                   
          performed a bank deposits plus cash expenditures analysis to                
          reconstruct petitioners’ income.                                            
               The revenue agent’s analysis, which is reproduced as the               
          appendix to this opinion, reflects these four steps:  First, the            






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  Next

Last modified: May 25, 2011