Sue Taylor - Page 6

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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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