- 11 -
charter business were $74,893, $215,427, and $320,532 in 1994,
1995, and 1996, respectively.
In the notice of deficiency, respondent determined that
petitioner’s gross receipts were $144,217, $415,018, and $364,247
in 1994, 1995, and 1996, respectively, resulting in
determinations of unreported gross receipts of $68,350, $190,615,
and $34,544 in those years.7 With respect to 1994, petitioner
subsequently admitted that he deposited charter receipts of
$116,095, an amount exceeding his reported charter gross receipts
by $41,202. He further admitted that in 1994 he made additional
deposits of funds from third parties totaling $29,247 and cash of
$7,000, but denied that these amounts represented charter
receipts. With respect to 1995, petitioner subsequently admitted
that he deposited charter receipts of $399,239, an amount
exceeding his reported charter gross receipts by $182,812. He
further admitted that in 1995 he made additional deposits of
funds from third parties totaling $5,733, but denied that this
amount represented charter receipts. With respect to 1996,
petitioner subsequently admitted that he deposited charter
receipts of $318,471, an amount that is $2,061 less than his
reported charter gross receipts. He further admitted that in
1996 he made additional deposits of funds from third parties
7 In determining unreported gross receipts, respondent made
adjustments for petitioner’s collection of sales tax.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011