George Steve Sasser and Tammy R. Sasser - Page 8




                                        - 7 -                                         
               Under the other variation of the analysis, respondent                  
          contends that Mr. Sasser had at least $6,730 of unreported income           
          in 1996:                                                                    

               Deposits to personal account          $29,096                          
               Less: Mrs. Sasser’s net wages         -17,267                          
               Balance                                11,829                          
               Less: Dec.‘96 credit card advance       - 11,500                       
               Balance                                10,329                          
               Less: Deposits attributable to                                         
               Mrs. Sasser’s brother           -13,600                                
               Unreported gross receipts               6,729                          
               1If proven                                                             

               Neither variation of respondent’s bank deposits analysis               
          takes into account the $1,730 tax refund that petitioners                   
          received in 1996.  This “omission” is appropriate because the               
          refund was not deposited in either of petitioners’ checking                 
          accounts and therefore need not be accounted for insofar as the             
          bank deposits analysis is concerned.                                        
               The gross receipts reported by Mr. Sasser on his Schedule C            
          were also not taken into account by either variation of                     
          respondent’s bank deposits analysis.  In this regard,                       
          respondent’s position seems to be that there was no commingling             
          of Mr. Sasser’s gross receipts between petitioner’s personal and            
          business checking accounts.  However, this position is contrary             
          to the weight of the evidence, and our findings reflect the fact            
          that Mr. Sasser’s gross receipts were commingled between                    
          petitioners’ two accounts.                                                  





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