- 20 -
Respondent determined that petitioner’s profits from his
consulting business should be increased by $24,016 for 1994,
$7,037 for 1995, and $13,094 for 1996, consisting of omitted
gross receipts and disallowed claimed business expenses.
In addition to compensation for his consulting services,
petitioner received reimbursement from his clients for expenses.
The reimbursements were not included in the compensation reported
on Forms 1099 issued by the clients but were deducted by
petitioner on the consulting business Schedules C. Petitioner
did not keep accurate records of his reimbursed expenses. The
invoices he submitted to the clients did not match deposits made
into his bank accounts. During the audit, petitioner identified
certain deposits as amounts he received from clients for services
and reimbursed expenses (the consulting business deposits).
In computing the gross receipts from petitioner’s consulting
business, respondent used the specific items method; i.e., the
consulting business deposits. The consulting business deposits
totaled $83,966 in 1994, $56,066 in 1995, and $63,651 in 1996.
At trial petitioner offered no evidence to establish that the
deposits were not amounts paid to him by his clients or were
nontaxable amounts. We find that petitioner’s gross receipts
from the consulting business were as determined by respondent;
namely $83,966 in 1994, $56,066 in 1995, and $63,651 in 1996.
Page: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: May 25, 2011