- 4 - (Riverbank West); Benz-Niva Corp. (Benz); R.F. Riverbend, Inc. (Riverbend); and High Western Development Corp. (High Western). No Federal corporate tax returns were filed for High Western, Benz, or Youwonder. Petitioner did not maintain adequate records of his business activity. Respondent reconstructed petitioner’s income from this activity by means of the specific items method, which involved tracking checking account transactions to petitioner or his related entities. Petitioner received income for personal services in real estate activity from some of the above-named corporations, as follows: Amount and Year Corporation 1992 1993 High Western $10,500.00 $3,800.00 Benz 63,426.50 12,000.00 Youwonder 1,688.00 11,662.00 Total 75,614.50 27,462.00 In performing the reconstruction of petitioner’s income for 1992 and 1993, respondent utilized checks that had been negotiated by petitioner and his related entities and backed out or removed certain items and transfers between accounts to avoid the possibility of double counting. Respondent’s audit was commenced after receipt of incomplete records of petitioner’s business activity from the State of Colorado. The State of Colorado had conducted a criminal examination and reviewed petitioner’s and his related corporations’ records to determinePage: Previous 1 2 3 4 5 6 7 8 9 10 11 Next
Last modified: May 25, 2011