- 6 - respondent’s agent estimated that petitioner had the following amounts of gross receipts: 1992 1993 1994 Returns prepared 724 756 700 Return preparer fee $25 $28 $26 RAL fee $30 $30 $30 Total fee per return x $55 x $58 x $56 Total gross receipts $39,820 $43,848 $39,200 Less gross receipts $4,695 $13,601 $22,895 reported Adjustment per notice of $35,125 $30,247 $16,305 deficiency (unreported income) OPINION A. Whether Petitioner Had Unreported Income in 1992-94 1. Positions of the Parties Respondent contends that petitioner understated his income by $35,125 for 1992, $30,247 for 1993, and $16,305 for 1994. Petitioner contends that he reported all of his income in 1992-94 and that respondent’s method of reconstructing his income is inaccurate. 2. Whether Respondent’s Determination Is Entitled to Presumption of Correctness The U.S. Court of Appeals for the Fifth Circuit, the circuit to which this case is appealable, has stated that, in casesPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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