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Appendix D
ITEMS RESPONDENT RELIES UPON AS
CLEAR AND CONVINCING EVIDENCE OF UNDERPAYMENT
1985:
Stipulated Income:
Income Item Amount
Miscellaneous Sch. C income $12,357
Gains from property sales 185,661
Interest income 40,479
Commission income 30,249
Unidentified deposits 1,700
Total stipulated income 270,446
Disputed Income:
Income Item Amount
Gain from sale of Lot 1 in
Susan’s Lakefront Estate $20,097
Installment gain from sale of
3 lots in Florida Fruit Belt Subd. 28,347
Gain from sale of installment note 30,925
Gain from sale of Lot 23, High Plains 19,699
Installment gain from Silver Lake sale 6,144
Gain from foreclosure sale of
Citrus County Property 112,156
Interest income from Silver Lake mortgage 6,773
Commission income 37,500
Rental income 1,250
Unidentified deposit 59,000
Total disputed income 321,891
Total income relied upon by respondent (stipulated income +
disputed income): $592,337
Less reconstructed Schedule C expenses
(after concessions on brief): $225,301
Less itemized deductions: $22,567
Less personal exemptions: $2,080
Taxable income: $342,389
Tax liability (based on head of household filing status):
$151,597
Plus self-employment tax: $4,673
CLAIMED UNDERPAYMENT FOR 1985: $156,270
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