- 22 -
Commissioner, 31 T.C. 1269 (1959), affd. in part and revd. in
part on another issue 283 F.2d 871 (6th Cir. 1960); Bolton v.
Commissioner, T.C. Memo. 1975-373.
Petitioner failed to produce records establishing his gross
receipts from his yacht charter business for 1994, 1995, and
1996. Using third-party records, respondent determined that
petitioner’s gross receipts were $144,217, $415,018, and $364,247
in 1994, 1995, and 1996, respectively, resulting in a
determination of unreported gross receipts of $68,350, $190,615,
and $34,544 in those years.
As outlined in our findings, with respect to 1994,
petitioner has admitted depositing charter receipts of $116,09514
and other amounts which bring total deposits to $152,342, as
compared to respondent’s determination that his gross receipts
were $144,217. With respect to 1995, petitioner has admitted
depositing charter receipts of $399,23915 and other amounts which
bring total deposits to $404,972, as compared to respondent’s
determination that his gross receipts were $415,018. With
respect to 1996, petitioner has admitted depositing charter
receipts of $318,471 and other amounts, which bring total
14 This figure exceeds petitioner’s reported gross receipts
for 1994 by $41,202.
15 This figure exceeds petitioner’s reported gross receipts
for 1995 by $182,812.
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