- 6 - expenses, and evidence showing that petitioners had acquired assets and made substantial expenditures, Agent McCarter decided to use an indirect method of proof to reconstruct Mr. Black’s income for 1991 and 1992. Agent McCarter ultimately determined that the net worth method would be the most appropriate method to use. Agent McCarter prepared a revenue agent’s report setting forth the results of her examination of petitioners’ returns for the taxable years 1991 and 1992. On June 9, 2004, respondent issued a statutory notice of deficiency to petitioners for taxable years 1991 and 1992. In the notice of deficiency, respondent determined petitioners’ taxable income for 1991 and 1992 using the net worth method of proof. Respondent determined that petitioners made nondeductible expenditures during taxable years 1991 and 1992 of $108,768.01 and $188,219.01, respectively. Mr. Black applied for a $250,000 life insurance policy. Mr. Black’s business wrote check No. 1908 dated 12/10/92 to First Colony Life Insurance Co. of $318.24 for a $50,000 life insurance policy on Mr. Black. Respondent’s net worth computations treat certain payments made by Mr. Black’s businesses during 1991 and 1992 for medical expenses as nondeductible personal expenditures made by petitioners.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: March 27, 2008