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to call. And I will just let the Government go ahead with the
case and proceed. I don’t believe that I owe the deficiencies
that they are claiming. And I’ll just let them go ahead and
bring forth their case. I rest my case.”
Because petitioner would not cooperate with or provide
documents for the audit, respondent computed petitioner’s income
using an indirect bank deposit analysis. This was accomplished
by examining copies of checks and bank statements and determining
whether the bank deposits reflected in the statements constituted
gross income to petitioner. Petitioner had signatory authority
over four accounts, which respondent contends are relevant to
this case: (1) Arizona Federal Credit Union (Account No. 136856
- Sue Taylor), (2) Norwest Bank Arizona, N.A. (Account No.
6056602931 - Sue Taylor d|b|a Nature’s Herb & Tea Garden), (3)
San Tan Credit Union (Account No. 8198 - National Land Bank LLC),
and (4) Arizona Federal Credit Union (Account No. 138022 - Sue
Taylor d|b|a Miroyal L.L.C.). In addition, respondent disallowed
expenses claimed on the filed tax returns for which no
substantiation was provided.
A. Miroyal LLC
1. Taxable Year 1999
On October 1, 2000, petitioner signed and then on October
18, 2000, filed Form 1065, U.S. Partnership Return of Income, on
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Last modified: May 25, 2011