- 2 - Respondent determined a deficiency in petitioners’ Federal income tax in the amount of $10,167 and an accuracy-related penalty under section 6662(a) of $1,728.40 for taxable year 1995. After petitioners’ concession,1 the issues for decision are: (1) Whether petitioners received unreported income of $22,082.25 for 1995, as suggested by unexplained bank deposits made by them during that year; and (2) whether petitioners are liable for an accuracy-related penalty under section 6662(a) for 1995. Background Some of the facts have been stipulated, and they are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. At the time of filing their petition, petitioners resided in Green Lane, Pennsylvania. During the year in issue, petitioner Jimie R. Overby (hereinafter petitioner) operated a general contracting business, while petitioner Sandra Herlitschek Overby operated a consulting business. Petitioners deposited the gross receipts from these two businesses into bank accounts opened at Quakertown National Bank. The bank accounts consisted of a checking account and a savings account. During the year in issue, petitioners made bank deposits totaling $103,072.44. Of this total amount, $50,657 is 1 Petitioners concede that they are not entitled to the claimed Schedule C, Profit or Loss From Business, deductions in the amount of $10,811 for the 1995 taxable year.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011