- 4 -
Petitioner did not timely file Form 1040, U.S. Individual
Income Tax Return, for taxable year 1993. Petitioner requested
an extension of time to file her 1993 Federal income tax return
and paid $300 therewith. Respondent extended the filing date for
petitioner's 1993 Federal income tax return from April 15, 1994
until August 15, 1994. On February 16, 1996, petitioner filed
her 1993 Federal income tax return. On December 17, 1997, the
IRS began its examination of petitioner's 1993 taxable year.
II. Unreported Income
During 1993, petitioner was an attorney, practicing as Joyce
Hastings, Attorney at Law. During 1993, petitioner deposited
amounts totaling $107,883.48 in her general business account.
The Schedule C, Profit or Loss From Business, attached to
petitioner’s 1993 Form 1040 reflected gross receipts of $55,442
from Joyce Hastings, Attorney at Law.
In the notice of deficiency, respondent determined that
petitioner failed to report $52,592 in gross receipts from her
law practice. Respondent subsequently conceded that deposits
totaling $6,100 were nontaxable transfers and that deposits
totaling $1,980 were pension and annuity income that petitioner
reported on her 1993 return. Respondent’s revised determination
is that petitioner had unreported taxable income of $44,361.48.
This amount is the result of subtracting petitioner’s reported
law practice gross receipts ($55,442) and the amount conceded by
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