- 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