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documents. Peterson rescheduled the conference for late November
2000.
Petitioner then retained Mr. Covarrubias (Covarrubias) to
represent him in his dealings with respondent. Covarrubias asked
Peterson to reschedule the conference for the end of December
2000. Peterson did so. Covarrubias attended that conference and
gave Peterson some of petitioner’s canceled checks. Covarrubias
later gave Peterson a box containing unorganized personal and
business invoices and petitioner’s credit card statements.
Warren organized petitioner’s records. Warren identified
the expenses which she thought were deductible. Warren then
recomputed petitioner’s income and expenses for 1996 and 1997 as
follows:
1996
Nontaxable items, Wells Fargo (2) $17,284.18
Nontaxable items, Bank of America 41,767.28
Returned deposits, Bank of America 8,613.32
Gross receipts per return 62,399.00
Unreported income 64,108.94
Total deposits for 1996 194,172.72
1997
Nontaxable items, Wells Fargo $560.00
Nontaxable items, Bank of America 65,232.54
Gross receipts per return 112,068.00
Unreported income 21,942.75
Total deposits for 1997 199,803.29
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