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1998 and 1999. During the examination of the Gownis’ income tax
returns, the IRS made requests for copies of workpapers and bank
statements. Because the Gownis did not produce adequate records
with respect to those requests, the IRS summonsed the Gownis’
bank records in order to make an appropriate determination of
their income for those years.
In determining the Gownis’ income for 1998, the IRS
summonsed and evaluated copies of (1) the bank statements from,
checks written for more than $500 on, and any items that were
listed on deposit tickets totaling $500 or more that were
deposited to the Gownis’ personal bank accounts at NationsBank,
First Union, Great Western Bank, Washington Mutual Bank, and
SunTrust for that year and (2) the statements from the Gownis’
personal VISA account for that year. In determining the Gownis’
income for 1999, the IRS summonsed and evaluated copies of the
bank statements from, checks written for more than $500 on, and
any items that were listed on deposit tickets totaling $500 or
more that were deposited to the Gownis’ personal bank accounts at
NationsBank, Washington Mutual Bank, and SunTrust for that year.
In addition, the IRS summonsed and evaluated the following
sources of information for purposes of determining the Gownis’
income for 1998 and 1999: (1) Additional documents from
NationsBank pertaining to the Gownis’ certificate of deposit;
(2) information related to the Gownis from the Money Transfer
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