Joyce H. Sams - Page 12




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          December 3, 1996; however, she did not produce a bank statement             
          from the account for the period December 4 through 31, 1996.                
          Because petitioner did not produce all of the requested records,            
          respondent reconstructed petitioner’s income by performing a bank           
          deposit analysis of her account.  Respondent determined in the              
          notice of deficiency that petitioner had unexplained deposits in            
          the account and, therefore, unreported gross income of $35,318.             
          Subsequent to the issuance of the notice of deficiency respondent           
          reduced this amount to $25,578 calculated as follows:                       
               Total deposits into account                  $99,381                   
               Returned checks                              (3,375)                   
               Deposits from home equity line of credit     (13,000)                  
               Income reported on return                    (57,428)                  
               Total unexplained deposits                   25,578                    
               In addition to the use of the bank deposit methodology,                
          respondent determined that petitioner received $12,589.55 in                
          commission income and $1,800 in teaching income from O’Brien,               
          based upon Forms 1099-MISC issued to Sams, Inc. and filed with              
          respondent.  Petitioner reported the teaching income of $1,800              
          but only $10,122 of the commission income in 1996.                          
               Petitioner asserts that the deposits into the account can be           
          explained from the following sources:                                       
               Returned checks                    $3,375                              
               Home equity line of credit         14,700                              
               1099-MISC O’Brien commissions      10,122                              
               1099-MISC O’Brien teaching         1,800                               
               Mack/Middleton interest            22,140                              
               Mack/Middleton reimbursement       3,881                               






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