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The gross receipts adjustments are the same as, and are directly
based upon, the net worth computations used in Mr. Del Bosque’s
criminal tax proceeding.
On December 12, 2000, respondent issued a notice of
deficiency to Mr. and Mrs. Jacobsen for 1987 and 1988. In that
notice of deficiency, respondent determined that Mr. Jacobsen
received, but failed to report, gross receipts of $28,378 in 1987
and $29,747 in 1988, computed as follows:
1986 1987 1988
Net worth computation:
Assets $330,569 $356,098 $441,985
Liabilities 144,741 152,332 159,418
Net worth 185,828 203,766 282,567
Less prior year’s net worth 185,828 203,766
Increase in net worth 17,938 78,801
Adjustments:
Additions:
Nondeductible expenses 46,965 45,866
Itemized deductions expenditures 15,295 18,967
Subtractions:
Nonincome items (2,051) (59,504)
Adjusted gross income 78,147 84,130
Itemized deductions (13,130) (14,857)
Personal exemptions (3,800) (3,900)
Corrected taxable income 61,217 65,373
Taxable income reported (32,839) (35,626)
Gross receipts 28,378 29,747
The gross receipts adjustments are the same as, and are directly
based upon, the net worth computations used in Mr. Jacobsen’s
criminal tax proceeding.
Respondent also increased the Jacobsens’ income by $6,285 in
1987 and $6,309 in 1988 using Bureau of Labor Statistics figures.
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