- 7 - as Coastal Builders, Agent Daniels found that petitioner deposited income of $3,651,293, $9,409,882, and $4,316,813 into various bank accounts in the respective years at issue. Respondent did not issue to petitioner or Mr. Townshend a 30-day letter setting out Agent Daniels’s findings. On September 15, 2004, petitioner filed a Form 1040 for 1999 reporting a tax liability of $11,155. The 1999 return included petitioner’s Schedule C for 1999 reporting gross receipts of $3,601,882 and costs of goods sold and expenses totaling $3,600,556.6 Based upon respondent’s bank deposits analysis, respondent determined that petitioner understated his Schedule C gross receipts in 1999 by $49,411.7 Petitioner did not assert in his petition or offer evidence to show he did not understate his income in 1999. Petitioner failed to file a return for 2000. Consequently, on June 15, 2005, respondent filed a substitute for return pursuant to section 6020(b), in which he determined petitioner received gross receipts of $9,409,882 in 2000. On brief, respondent conceded petitioner only received gross receipts of $9,009,882 for 2000. Petitioner failed to make estimated tax 6 The $3,600,556 comprised costs of goods sold of $2,932,248, and deductions of $668,308. 7 $3,651,293 (bank deposits) - $3,601,882 (reported Schedule C gross receipts) = $49,411 understatementPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 NextLast modified: November 10, 2007