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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 cases
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