- 68 - brief that they calculated gross receipts incorrectly or whether they incorrectly described their method of calculation. Lastly, because petitioners were cash basis taxpayers, it would not be surprising to find that the amount reported on a Form 1099 is different from the total amount of the corresponding invoices. The Form 1099 amount may be less in situations where the customer paid only part or some of the invoices. The Form 1099 amount may be greater than the total amount of the corresponding invoices in situations where the customer paid for services rendered in prior years. Thus, it is possible, as petitioners contend, that the discrepancies are due to “timing considerations”. Petitioners, however, have not provided us with any records from which we can ascertain the actual relationships between the Form 1099 amounts and Michael’s plumbing business receipts for the years in issue. Accordingly, based on the record as a whole, we conclude that Michael’s books and records are sufficiently confused so that they do not reliably show the gross receipts from the plumbing business, and consequently, Michael’s tax liabilities, for the years in issue. (3) Inconsistent and Implausible Explanations Petitioners attribute a significant portion of their bank deposits for the years in issue to Michael’s cash hoard. Respondent maintains that petitioners’ explanations and behaviorPage: Previous 56 57 58 59 60 61 62 63 64 65 66 67 68 69 70 71 72 73 74 75 Next
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