Michael J. Downing and Sandra M. Downing - Page 67

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          as gross receipts because those totals reflect the amounts due              
          for work done, not the amounts received for the work.  As such,             
          Sandra’s computational error in adding together the invoices for            
          1995 is irrelevant to the determination of the amount that should           
          have been reported on the Schedule C.  Nevertheless, this error             
          in bookkeeping suggests that petitioners’ records for the years             
          in issue are insufficient to show Michael’s tax liabilities.                
               Secondly, petitioners, for the first time on answering                 
          brief, appear to argue that the adding machine tape totals                  
          represent the amounts received by the plumbing business, not the            
          total amount of the invoices.  In response to respondent’s                  
          proposed finding of fact that Sandra understated, by a total of             
          $8,683, the amounts of four invoices shown on the adding machine            
          tapes, petitioners claim that they did not have to report that              
          $8,683 because they did not receive it.  If petitioners did not             
          receive the $8,683 in 1995, then they are correct that Michael              
          was not required to report that amount on the Schedule C.                   
          However, as stated above, Sandra testified that she calculated              
          gross receipts by adding together the invoices, not the receipts.           
          And the parties stipulated that Sandra provided to the revenue              
          agent copies of the adding machine tapes along with the invoices            
          used to calculate gross receipts for the plumbing business.  We             
          do not know whether petitioners did not realize until answering             








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