Alber I. and Georgette H. Said - Page 5

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          conducted a bank deposits analysis of petitioners’ accounts.                
          After allowing for nontaxable transfers, Pascual determined that            
          petitioners had unreported gross receipts deposited into their              
          bank accounts in each of the years in issue.                                
               Petitioners did not provide complete records of Mena’s                 
          expenses, instead turning over various incomplete and disorderly            
          receipts and documents.  To calculate Mena’s cost of goods sold,            
          Pascual relied on two documents provided by petitioners.  Pascual           
          reviewed an ARCO Products Company, Product Sales for Customer               
          spreadsheet that indicated how much gasoline was sold to Mena’s             
          and a Summary of Items Collected from ARCO Productions Company.             
          Pascual determined the cost of goods sold by calculating the                
          amount of gasoline and other items sold based on these two                  
          documents and substantiating invoices.                                      
               Pascual also reviewed Mena’s daily cash log of gasoline                
          sales for all 3 years.  Pascual added the amounts from the log on           
          his adding machine, keeping a copy of the tape and returning the            
          original log to petitioners.  Subsequently, petitioners disputed            
          Pascual’s tape totals for 1995 and again provided the daily log             
          sheets.  Before resubmitting the daily log sheets to Pascual,               
          petitioner altered the amounts on the logs and made erasures.               
               During the audit, Pascual questioned whether petitioners               
          received gross receipts from automobile repairs.  Petitioner told           
          Pascual that Mena’s conducted smog checks and engaged in tuneups            






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