James C. Blanning, Jr. - Page 4

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          (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 determine             





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