- 6 - After petitioner filed his amended 1989 and 1990 returns and his original 1991 return, respondent was forced to summons petitioner’s records to verify the income and deductions reported by petitioner. The summonsed records generally did not agree with petitioner’s tax returns. In addition, records provided by petitioner to respondent’s agent were not properly organized or categorized. Petitioner’s 1990 records contained duplications and personal expense receipts. Due to the discrepancies and poor records, respondent’s agent reconstructed petitioner’s 1990 income by means of a bank deposit analysis. Petitioner’s deductions were determined by means of analyzing the records summonsed and provided by petitioner. Respondent’s bank deposits reconstruction of petitioner’s income revealed that petitioner had unexplained deposits which petitioner omitted from his original 1990 return. Respondent’s determination for petitioner’s 1990 income was that he failed to report specific identified gross receipts of $17,572 from Medicaid administrative fees and $129,136 from taxi leasing. Respondent’s agent was able to verify $127,879 of petitioner’s claimed deductions of $211,875 for 1990. With respect to 1991, respondent’s agent was able to verify $112,023 of the $254,787 petitioner claimed as business deductions. After the petition was filed, based on petitioner’s further substantiation, respondent allowed an additional $45,184 in taxiPage: 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