Winston Knauss - Page 11

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          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.                       





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