- 6 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011