- 9 - petitioner’s and Ms. Shaw’s 1993 and 1994 returns related to Ms. Shaw’s store. Petitioner timely filed his 1995 return as a single person. On that return, he reported $221,000 in gross receipts from Far Eastern, but he understated gross receipts from Far Eastern by $338,276, and overstated net rental income by about $5,000. D. Respondent’s Determination Revenue Agent Claude Williams (Williams) began to examine petitioner’s 1993-95 returns before July 23, 1998. Petitioner cooperated fully with Williams during the examination. Petitioner signed a document allowing Williams to review petitioner’s bank records. Williams asked petitioner to complete a lengthy form to provide information about his personal living expenses during the years in issue. Petitioner completed the form with information that Williams believed was fair and complete. Petitioner did not have many records for Far Eastern. As a result, Williams reconstructed petitioner’s gross receipts for 1993-95 using the bank deposits method. To reduce photocopying costs, Williams did not obtain copies of petitioner’s bank deposit records or canceled checks for the years in issue. Williams obtained records for Far Eastern from the Customs Service, Panalpina, and Henry’s Gifts. He used those records to try to reconstruct petitioner’s shipping costs. The PanalpinaPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011