Albert M. Graham and Martha A. Graham - Page 24

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          that were used for both his home and office.  He said Edgar had             
          misclassified personal expenses as business expenses; however,              
          petitioners improperly deducted $4,476 of personal expenses as              
          business expenses in 1999 after Edgar was fired.                            
               Petitioner incorrectly told Peredo that he did not have any            
          books or billing records because Edgar had them.                            
               Petitioner incorrectly told Peredo that he did not engage in           
          bartering.  Petitioner bartered his services in exchange for                
          services provided by some of his clients.  For example, Thomas              
          owed petitioner $2,300 for petitioner’s representation of Thomas            
          in a custody battle with his ex-wife over visitation rights of              
          their son.  Thomas subtracted that amount from the amount                   
          petitioner owed him for the kitchen remodeling job.                         
          F.   Respondent’s Bank Deposits Analysis                                    
               The revenue agent performed a bank deposits analysis and               
          characterized each of petitioner’s deposits in his business                 
          account as taxable or nontaxable.                                           
               Petitioner deposited $572,284 in his law firm's business               
          checking account in 1998.  Included in those deposits were                  
          $55,971 from nontaxable sources, as follows: (a) $40,873 allowed            
          by the revenue agent in preparing the notice of deficiency; (b)             
          $10,098 in checks from Edgar traceable to the funds transferred             
          to her from the $135,422 deposited in O’Leary’s account; and (c)            







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