Monty Bisceglia and Patricia Bisceglia - Page 6





                                        - 6 -                                         

          income by comparing changes in their net worth from 1 year to the           

          next for the 3 years in issue.  Respondent’s net worth analysis             

          is as follows:3                                                             

                            Net Worth Expenditures Computation                        
               Assets              12/31/92  12/31/93  12/31/94  12/31/95             
          Cash on hand             $2,500    $2,500    $2,500    $2,500               
          Cash in banks            220       2,639     7,277     21,877               
          Notes receivable         –         115,000   111,359   107,357              
          Inventory                20,477    18,514    12,000    18,221               
          Investments              821,000   654,000   889,621   762,000              
          Net accounts receivable  9,000      171,000   105,200   99,000              
          Total assets             853,197    963,653   1,127,957   1,010,955         
          Liabilities & Accum Depr                                                    
          Notes & loans payable    $409,938  $406,899  $653,369  $402,947             
          Accumulated depreciation –-          –       1,873     3,746                
          Total liabilities &      409,938   406,899   655,242   406,693              
          Accum depr                                                                  
          Net worth                443,259   556,754   472,715   604,262              
          Less beginning net worth           443,259   556,754   472,715              
          Increase in net worth              113,495   (84,039)  131,547              
          Add: Personal expenses             29,148    58,972    26,628               
          Adjustments (capital loss         (1,800)     –-          –                
          not deducted)                                                               
          Corrected adjusted gross                                                    
          income                             140,843   (25,067)  158,175              
          Adjusted gross income              (11,652)  16,270    18,635               
          reported                                                                    
          Unreported income                  152,495   141,337   139,540              
               1 It appears that $41,337 should be a negative figure, rather than     
          positive unreported income as indicated on respondent’s net worth analysis. 
          Consistent with this conclusion, respondent has determined no 1994 deficiency
          arising from any unreported income indicated by the net worth analysis.     
          Petitioners have not raised, and we do not reach, any issue as to whether any
          part of any 1994 net loss should be deductible in 1993 or 1995 as a net     
          operating loss carryback or carryover.  See sec. 172.                       
               The following table, as set forth in respondent’s Answer to            

          Amended Petition, shows the particular assets and                           



               3 This table, as set forth in respondent’s Answer to Amended           
          Petition, reflects certain adjustments to the net worth analysis            
          upon which the notice of deficiency was predicated, as discussed            
          in more detail, infra.                                                      






Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  17  18  19  20  Next

Last modified: May 25, 2011