- 24 - 1935); see also United States v. Abodeely, 801 F.2d 1020, 1023- 1025 (8th Cir. 1986); Caulfield v. Commissioner, T.C. Memo. 1993- 423, affd. 33 F.3d 991 (8th Cir. 1994). The bank deposits method is often used in cases in which the taxpayer maintained inadequate, incomplete, or unclear records. See, e.g., Holland v. United States, 348 U.S. 121 (1954); DiLeo v. Commissioner, 96 T.C. 858, 867 (1991), affd. 959 F.2d 16 (2d Cir. 1992); Estate of Mason v. Commissioner, 64 T.C. 651, 656 (1975), affd. 566 F.2d 2 (6th Cir. 1977). In this case, petitioner produced records of her taxable income, including her Schedule C income. The records included handwritten ledger books as well as bank records such as bank statements and deposit tickets. A review of petitioner’s income records establishes to the Court’s satisfaction that the gross income reported on petitioner’s Schedules C for 1987 and 1989 was derived from petitioner’s handwritten ledger books and was not calculated based on deposits into petitioner’s bank accounts. The return preparer, Mr. Aunan, took the gross receipts numbers that petitioner derived from her ledger books for the years at issue and adjusted the numbers for any refunds made to petitioner’s clients during the taxable years. In 1987 Mr. Aunan made no adjustments to petitioner’s Schedule C gross receipts of $75,097, but, in 1989, Mr. Aunan reduced the preliminary gross receipts figure of $129,146 by client refunds of $470 andPage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011