- 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
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