-3- 1995 return that the business income consisted of $12,000 received by William McDermott (Mr. McDermott) and $18,000 received by Donna McDermott (Ms. McDermott). During 1995, Mr. McDermott was an independent contractor who bought and sold educational textbooks as the manager of Omega Resources LLC (Omega). He generally works for Omega throughout the United States, and it reimburses him for his out-of-pocket traveling expenses. Ms. McDermott also worked for Omega during that year as an independent contractor. She has an undergraduate degree in teaching and a master’s degree in the healing arts (the study of alternative medicine), and she worked for Omega counseling individuals on their personal problems. During 1995, petitioners had a regular checking account at First Interstate Bank (FIB), two valuechecking accounts at Bank One, and a securities account at Prudential Securities. When respondent audited petitioners’ 1995 return, respondent performed a bank account analysis on these four accounts and determined in the notice of deficiency that the following 23 deposits into the FIB and Bank One accounts were includable in petitioners’ 1995 gross income: Date of Deposit Amount Jan. 18 $1,375 Apr. 7 150 May 10 93 May 10 475 May 10 151 May 10 156Page: Previous 1 2 3 4 5 6 7 Next
Last modified: May 25, 2011