James J. McCarron III and Michelle McCarron - Page 7

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                              1993           143 returns                              
                              1994    139 returns                                     
                              1995    236 returns                                     
               Petitioner gave respondent information indicating that he              
          had prepared returns as follows:                                            
                                   1993      82 returns                               
                                   1994      76 returns                               
                                   1995      66 returns                               
               Respondent compared the IRS database listing to the                    
          corresponding deposits of fees into petitioners' bank accounts              
          and identified an additional 69 returns prepared by petitioner in           
          1995 alone.  Ten of those returns were business returns which               
          would not have appeared in the IRS database.  For tax year 1995,            
          at least 111 returns and their related preparation fees were not            
          identified as having been deposited, in whole or in part.                   
               Respondent determined petitioners had omitted gross receipts           
          received from petitioner's Schedule C tax return preparation                
          business of $10,885 for 1993, $12,247 for 1994, and $14,135 for             
          1995.                                                                       
               After reducing total unexplained bank deposits by unreported           
          fees identified by respondent as well as income reported on Forms           
          W-2, Wage and Tax Statement, and Forms 1099-MISC, Miscellaneous             
          Income, respondent's analysis determined petitioners had                    
          remaining unexplained bank deposits as follows:                             
                                   1993      $24,508                                  
                                   1994      26,300                                   
                                   1995      12,095                                   






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