Peter and Mary Possas - Page 7




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          Respondent’s Determination of Omitted Income for 1996                       
               Respondent first examined petitioners’ 1996 tax return.                
          Respondent allowed the claimed advertising expense with respect             
          to Mr. Possas’s activity; however, respondent disallowed the                
          claimed expenses relating to the hairdressing activity.                     
          Respondent also reconstructed petitioners’ income and prepared a            
          bank deposit analysis.  The examiner totaled the deposits made in           
          1996 into each of petitioners’ bank accounts and then traced                
          these deposits to known sources of income, such as wages reported           
          on the return and Forms W-2, Wage and Tax Statement, prizes and             
          awards, redeposited liquidated certificates of deposit (CDs), and           
          transfers between accounts.  Respondent assumed that the                    
          unexplained deposits were the gross receipts from Mrs. Possas’s             
          hairdressing activity.                                                      
               The examiner concluded that petitioners were “entitled to              
          some form of expense, because you cannot be a beautician without            
          having to spend something”.  The examiner used statistics from              
          the Bureau of Labor Statistics (BLS) to calculate the “profit               
          margin” for a beautician using a “gross profit percentage”, which           
          was 65 percent, and applied this profit margin to the                       
          reconstructed gross receipts.3  This application resulted in                



               3  Respondent used figures for beauticians available from              
          the Bureau of Labor Statistics from a document entitled “Sole               
          Proprietorship Returns from 1994”.  The figures are for net                 
          income and take average industry expenses into consideration.               




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