Ragnhild A. Westby - Page 5

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          Proprietorship), reporting the income, expenses, and profit or              
          loss from petitioner’s law practice.  Petitioner’s Schedules C              
          listed gross income, deductions, and net profit (loss) in the               
          following amounts:                                                          
          Year      Gross income        Deductions     Net profit (loss)              
          1987      $75,097             $76,198        $(1,101)                       
          1988      128,896             121,459             7,437                     
          1989      124,463           115,690               8,773                     
          1990      95,730              124,543        (28,813)                       
          II.  Respondent’s Adjustments to Petitioner’s Schedule C Income             
          and Deductions in the Notices of Deficiency                                 
               A.  Adjustments to Income                                              
               Respondent increased petitioner’s Schedule C gross income4             
          for the years in issue in the following amounts:                            
                         Year         Adjustment                                      
                         1987           $77,811                                       
                         1988           117,819                                       
                         1989           116,483                                       
                         1990           154,069                                       
          Respondent based the adjustments to petitioner’s Schedule C gross           
          income on two personal financial statements that petitioner                 
          submitted to American National Bank (ANB) in St. Paul (the                  
          financial statements).  Petitioner submitted the first financial            
          statement, dated December 22, 1987 (the 1987 financial                      
          statement), in connection with her purchase of a home and the               


               4Petitioner’s gross income equaled her gross receipts in               
          each of the years at issue because she was a cash basis taxpayer            
          and had no cost of goods sold during those years.                           





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