Charles Shaw - Page 9

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          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 Panalpina              






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