- 8 - Petitioners do not dispute respondent’s use of the bank deposits method of reconstruction and do not allege any specific error in respondent’s computations. Rather, we understand petitioners to contend that they maintained business records during the years in issue that were subsequently lost or destroyed, that the 2000 and 2001 tax returns accurately reported petitioners’ income and expenses for the years in issue in accordance with their lost or destroyed business records, and that respondent’s determinations are therefore erroneous. The record demonstrates that petitioners failed to produce books and records from which respondent could determine their tax liability for the years in issue. Consequently, we conclude that respondent’s use of the bank deposits method was proper. See Estate of Mason v. Commissioner, supra. The record further demonstrates that respondent properly computed the gross receipts and business expenses for petitioners’ 2000 and 2001 tax years under the bank deposits method, as discussed below. With respect to petitioners’ gross receipts, the parties stipulated that deposits into the bank accounts during 2000 totaled $222,467.13, including $90,804.03 of nontaxable items and $16,135.08 of transfers.4 Additionally, the parties stipulated that deposits into the bank accounts during 2001 totaled 4We note that such “transfers” are nontaxable and could have been grouped together with the other nontaxable items.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011