Robert M. Johnson and Janna D. Begole, f.k.a. Janna D. Johnson - Page 5




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          provided to respondent’s Appeals officer a canceled check as                
          evidence of an additional $4,000 interbank transfer, and                    
          respondent credited DUI for the additional $4,000 interbank                 
          transfer when determining DUI’s unreported income for 1993.                 
               Set forth below is a summary schedule that reflects                    
          respondent’s calculation of DUI’s unreported gross income for               
          1992 and 1993:                                                              

                                      1992              1993                          
          Bank Deposits            $ 548,309         $ 488,841                        
          Less Reductions                                                             
          Returned Checks          (18,812)          (17,179)                         
          Refunds to Clients       (7,148)           (7,888)                          
          Interbank Transfers            (40,850)          (16,356)                   
          Gross Receipts           $ 481,499         $ 447,418                        
          Gross Receipts as Reported      (473,156)         (429,186)                 
          Unreported Gross Income      $   8,343         $  18,232                    

               On its S corporation tax returns for 1992 and 1993, DUI                
          claimed as “other deductions” business expenses of $27,020 and              
          $65,336, respectively.                                                      
               On audit, respondent determined that a portion of DUI’s                
          claimed business deductions for the years in issue was not                  
          allowable.  The deductions claimed by DUI and the amounts                   
          disallowed and allowed by respondent are reflected in the                   
          schedule below:                                                             











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