Katrina L. Price - Page 6




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          D.   Respondent’s Reconstruction of Petitioner’s Income                     
               The examination began on April 23, 1997.  Alex Malichiwski             
          (Malichiwski), respondent’s revenue agent, examined petitioner’s            
          1993 and 1994 returns.  He issued summonses to petitioner’s banks           
          for petitioner’s records.  Citibank and Chemical Bank gave                  
          Malichiwski copies of petitioner’s bank statements and checks for           
          1993, 1994, and 1995.1  Malichiwski reconstructed petitioner’s              
          income for 1993 and 1994 because petitioner did not have records.           
          He used a modified bank deposits method in which he assumed that            
          deposits of less than $1,000 (hereinafter referred to as small              
          deposits), totaling $12,363 in 1993 and $12,677 in 1994, were               
          petitioner’s wages from the photo shop.  He did not include the             
          deposit from the reported gambling winnings in 1994 as income in            
          the modified bank deposits method because petitioner had reported           
          the $20,046 on her 1994 return.                                             
               Malichiwski concluded that 10 of petitioner’s bank deposits            
          of $1,000 or more in 1993 (totaling $25,500) were unreported                
          income because petitioner did not establish to his satisfaction             
          during the examination that those funds were not taxable income             
          to her.  He concluded that, of petitioner’s six bank deposits of            
          $1,000 or more in 1994 (totaling 11,267.47), deposits of $4,000             




               1  The banks did not have copies of all of petitioner’s                
          checks.                                                                     





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