Frank H. and Marla C. Black - Page 11
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Petitioners were unable to estimate, in dollars, the amounts
of the alleged cash hoard they contend were expended during
either 1991 or 1992. Petitioners failed to provide any specific
details (i.e., dates, amounts, or items purchased) concerning the
use of the alleged cash hoard during either 1991 or 1992 for
either personal or business purposes.
All of the nondeductible expenditures Agent McCarter took
into account in her net worth computation were paid either by
check, or by credit card charges later paid by check.
The cash deposits into petitioners’ bank accounts totaled
$4,500 in 1991, and no cash deposits were made into petitioners’
bank accounts during 1992.
Petitioners claimed net operating loss deductions of $19,008
and $29,917 on their 1991 and 1992 joint returns respectively.
Petitioners claimed $3,000 deductions for short-term capital
losses on their 1991 and 1992 joint returns.
In the notice of deficiency, respondent determined that
petitioners omitted from their 1992 joint return interest income
of $3,748 and dividend income of $35 that they received from
American Funds Service Company.
Agent McCarter based her adjustments to petitioners’ 1992
interest income upon Forms 1099 issued in Mr. Black’s name and
Social Security number. None of the Forms 1099 were issued in
the name or employer identification number of Frank Black, Inc.
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Last modified: March 27, 2008