Patricia Barranco - Page 15




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          See Hayman v. Commissioner, 992 F.2d 1256, 1261 (2d Cir. 1993),             
          affg. T.C. Memo. 1992-228; Terzian v. Commissioner, 72 T.C. 1164,           
          1170 (1979).  Petitioner is thus deemed to have known, for                  
          example, the amounts of taxable income and adjusted gross income            
          reported on the joint returns.  Although the record does not                
          reveal with specificity the total amount of adjusted gross income           
          the Barrancos reported over the 10 years at issue, it does reveal           
          that the total amounts reported were understated by $5,878,813.             
          The annual shortfalls ranged from a low of $464,142 (in 1992) to            
          a high of $805,819 (in 1983).  For the years 1987-92 (the only              
          years for which the record reveals the amounts of gross income              
          reported on the Barrancos’ joint returns), the omitted gross                
          income exceeded the amounts of reported adjusted gross income by            
          an annual average of over 670 percent.  On the basis of the                 
          limited evidence in the record, it appears that the pattern of              
          underreporting for the years 1983-86 was similar.9                          
               What became of these large amounts of omitted income?  From            
          the limited evidence in the record, we can only conclude that               
          they were used largely to finance the Barrancos’ substantial                


               9 The Barrancos’ 1987-92 joint returns reported total                  
          adjusted gross income of $732,632 and omitted gross income of               
          $3,354,291.  The record does not contain the Barrancos’ 1983-86             
          joint returns or otherwise reveal the amount of adjusted gross              
          income they reported for those years.  The record does indicate,            
          however, that for those years the Barrancos reported total                  
          taxable income of $164,787, while omitting gross income of                  
          $2,524,522.                                                                 





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