4.10.3.5
(03-01-2003)
Examination
of
the
Taxpayer’s
Books
and
Records
The
examination
of
the
taxpayer’s
books
and
records
serves
two
basic
purposes:
To
analyze
the
likelihood
that
there
are
no
material
errors;
To
determine
that
individual
transactions
are
valid
(allowable),
have
not
been
omitted,
are
recorded
at
the
correct
dollar
value,
are
properly
classified,
and
are
recorded
in
the
correct
time
period.
This
section
includes
basics
steps
for
analyzing
and
testing
the
taxpayer’s
books
and
records.
4.10.3.5.1
(03-01-2003)
Step
1:
Determination
of
Available
Books
and
Records
The
first
step
is
to
determine
what
books
and
records
are
available
for
examination.
Taxpayers
may
present
receipts
and
cancelled
checks
as
verification
for
items
on
the
return.
A
business
may
use
a
single
entry
system
with
daily,
weekly,
or
monthly
entries
and
total,
or
a
double-entry
system.
The
routine
bookkeeping
may
be
accomplished
through
computerized
or
manual
means.
If
the
taxpayer
is
under
a
record
retention
agreement
with
the
Service,
they
must
maintain
magnetic
tapes,
disks,
or
other
machine
sensible
data
or
media
used
for
recording,
consolidating,
and
summarizing
accounting
transactions
and
records
within
the
taxpayer’s
processing
system.
See
Rev.
Proc.
91–38
for
further
information
on
Record
Retention
Agreements.
4.10.3.5.2
(03-01-2003)
Step
2:
Taxpayer
Explanation
of
Books
and
Records
The
second
step
is
to
have
the
taxpayer
explain
the
books
and
records.
The
accounting
and
record
keeping
system
should
be
explained
by
the
person
most
knowledgeable
of
the
system.
The
appropriate
person
may
be
the
taxpayer,
an
employee
of
the
taxpayer,
or
the
taxpayer’s
representative.
The
key
is
that
the
person
must
have
knowledge
of
the
taxpayer’s
accounting
system.
The
taxpayer’s
explanation
of
the
books
and
records
should
include:
Explaining
the
flow
of
transactions
or
entries
from
the
initial
transaction,
through
all
book
entries
and
reconciliations
to
the
tax
return.
Tracing
specific
income,
expense,
and,
if
applicable,
balance
sheet
items
through
the
accounting
system
(an
accounting
system
includes
all
books
of
entry
and
all
reconciliations).
If
applicable,
tracing
the
flow
of
purchases
and
inventory
through
to
Cost
of
Goods
Sold.
Note:
These
steps
will
also
be
used
to
evaluate
the
taxpayer's
internal
controls
as
described
above.
4.10.3.5.3
(03-01-2003)
Step
3:
Determination
of
Accounting
Period
The
third
step
is
to
determine
the
taxpayer’s
accounting
period.
"Annual
Accounting
Period"
means
the
annual
period
regularly
used
by
the
taxpayer
to
compute
income
and
maintain
books
and
records
(IRC
section
441(c)).
The
term
"taxable
year"
means:
The
taxpayer’s
annual
accounting
period,
if
it
is
a
calendar
year
or
a
fiscal
year;
or
The
period
for
which
the
return
is
made,
if
a
return
is
made
for
a
period
of
less
than
12
months.
See
IRC
section
441(b)
for
other
taxable
years.
A
tax
year
is
adopted
when
a
tax
return
for
the
taxpayer
is
filed
by
the
due
date
(not
including
extensions)
of
the
taxpayer’s
first
taxable
year.
Examples:
A
new
corporate
taxpayer,
with
a
fiscal
year
ending
August
30,
has
until
November
15
of
that
same
year
to
file
its
first
tax
return,
to
adopt
this
taxable
year.
A
new
individual
taxpayer,
with
a
calendar
year,
has
until
April
15
of
the
subsequent
year
to
file
his/her
first
tax
return,
to
adopt
this
taxable
year.
A
new
corporate
taxpayer,
with
a
calendar
year,
has
until
March
15
of
the
subsequent
year
to
file
its
first
tax
return,
to
adopt
this
taxable
year.
Allowable
accounting
periods
include:
Calendar
year,
ending
December
31
—
A
calendar
year
is
required
if
the
taxpayer
does
not
keep
books,
does
not
have
an
accounting
period,
or
has
an
accounting
period
that
does
not
qualify
as
a
fiscal
year.
Fiscal
year,
ending
on
the
last
day
of
a
month
other
than
December.
Note:
If
the
taxpayer
intends
to
choose
a
fiscal
year,
adequate
books
of
account
must
be
established
before
the
end
of
the
first
accounting
period.
52–53
week
period.
A
short
tax
year
is
one
of
less
than
12
months.
The
following
two
situations
can
result
in
a
short
tax
year:
When
a
taxable
entity
is
not
in
existence
for
an
entire
tax
year.
Income,
expenses,
and
tax
are
computed
solely
for
the
period
of
time
the
entity
is
in
existence.
When
an
existing
taxable
entity
changes
or
is
required
to
change
its
accounting
period.
In
this
case,
income,
expenses,
and
tax
must
be
annualized.
Example:
A
corporation
files
a
tax
return
because
of
a
change
in
accounting
period
for
the
6
month
short
tax
period
ending
June
30.
The
corporation
has
taxable
income
of
$40,000
during
the
short
tax
year.
Its
annualized
income
is
$80,000
($40,000
x
12/6)
.
Its
total
tax
(as
annualized)
is
$15,450.
The
tax
for
the
short
year
is
$7,725
($15,450
x
6/12).
Generally,
partnerships,
S
corporations,
and
personal
service
corporations
must
use
a
calendar
year
unless:
A
business
purpose
is
established
for
another
tax
year,
or
A
section
444
election
is
made.
In
general,
the
taxpayer
must
obtain
the
consent
of
the
Commissioner
to
change
the
accounting
period.
Treas.
Regs.
1.442-1(a)(1).
The
guidelines
for
obtaining
this
consent
are
contained
in
Rev.
Proc.
92–13,
1992-1
C.B.
665,
as
modified
by
Rev.
Proc.
92–13A,
1992-1
C.B.
668.
Treas.
Reg.
1.442-1(c)
provides
a
special
rule
for
certain
corporations
to
change
the
annual
accounting
period
without
the
prior
approval
of
the
Commissioner
if
all
the
following
conditions
are
met:
The
corporation
has
not
changed
its
annual
accounting
period
within
the
10
calendar
year
period
ending
with
the
calendar
year
that
includes
the
beginning
of
the
short
period
required
to
effect
the
change,
The
short
period
required
to
effect
the
accounting
period
change
is
not
a
taxable
year
in
which
the
corporation
has
a
net
operating
loss,
The
taxable
income
for
the
short
period
is,
if
placed
on
an
annual
basis,
80%
or
more
of
the
taxable
income
for
the
tax
year
immediately
preceding
the
short
period,
The
corporation,
if
it
had
a
special
status
(as
defined
in
section
1.442-1(c)(2)(iv))
either
for
the
short
period
or
for
the
tax
year
immediately
preceding
the
short
period,
must
have
the
same
special
status
for
both
the
short
period
and
the
preceding
tax
year,
and
The
corporation
does
not
attempt
to
elect
S
corporation
status
for
the
tax
year
immediately
following
the
short
period.
4.10.3.5.4
(03-01-2003)
Step
4:
Determination
of
the
Taxpayer’s
Method
of
Accounting
The
fourth
step
is
determining
the
taxpayer’s
method
of
accounting.
An
accounting
method
is
a
system
for
stating
income,
expenses,
assets,
liabilities,
and
financial
position.
Taxable
income
must
be
computed
not
only
on
the
basis
of
a
fixed
accounting
period,
but
also
in
accordance
with
a
method
of
accounting
regularly
employed
in
keeping
the
taxpayer’s
books.
An
accounting
method
is
selected
when
the
first
tax
return
is
filed.
IRC
Section
446(d)
states
a
taxpayer
may
compute
taxable
income
under
any
of
the
following
methods
of
accounting:
The
cash
receipts
and
disbursements
method,
An
accrual
method,
Any
other
method
permitted
by
this
section,
or
any
combination
of
the
foregoing
methods
permitted
under
regulations
prescribed
by
the
Secretary
(hybrid
methods).
There
are
special
methods
of
accounting
for
the
following
income
and
expense
items:
Depreciation
(IRC
sections
167
and
168).
Amortization
(IRC
sections
169,
178,
194,
and
197).
Depletion
(IRC
sections
611,
612,
613,
and
613A).
Deduction
for
Bad
Debts
(IRC
sections
166
and
582).
Installment
Sales
(IRC
sections
453
and
453B).
Long
Term
Contracts
(IRC
section
460).
A
taxpayer
engaged
in
more
than
one
trade
or
business
may,
in
computing
taxable
income,
use
a
different
method
of
accounting
for
each
trade
or
business.
A
reasonable
(hybrid)
method
may
be
used,
subject
to
the
following
restrictions:
If
inventories
are
present,
the
accrual
method
must
be
used
for
purchases
and
sales.
If
the
cash
method
is
used
to
compute
income,
the
cash
method
must
be
used
to
compute
expenses.
If
the
accrual
method
is
used
for
reporting
expenses,
the
entire
accounting
method
must
be
accrual.
If
the
taxpayer
selects
an
erroneous
accounting
method
when
the
first
return
is
filed,
it
can
be
corrected
by
filing
an
amended
return
before
the
filing
of
the
next
year’s
return.
All
other
accounting
method
changes
can
only
be
done
with
the
permission
of
the
Commissioner.
See
paragraph
(9)
below.
The
Service
can
prescribe
a
method
of
accounting
that
will
"
clearly
reflect
income"
if,
in
the
Service’s
opinion,
the
taxpayer’s
method
does
not
clearly
reflect
income.
A
method
does
not
clearly
reflect
income
if
all
items
of
income
and
expense
are
not
treated
with
reasonable
consistency
(see
paragraph
(9)
below).
Taxpayers
may
obtain
the
consent
of
the
Commissioner
to
voluntarily
change
their
method
of
accounting.
In
addition,
an
examiner
may
require
a
taxpayer
to
change
from
an
improper
method
of
accounting
to
a
proper
one.
The
Service
has
issued
a
series
of
revenue
procedures
to
provide
guidance
and
procedures
for
changes
in
method
of
accounting,
whether
voluntary
or
involuntary.
Examiners
must
ensure
that
they
are
familiar
with
the
applicable
guidance
in
effect
for
the
tax
year
under
examination.
The
most
recent
guidance
is
available
on
the
Change
in
Accounting
Method
(CAM)
Technical
Advisor
web
page
located
through
the
LMSB
Intranet
site.
For
additional
details
concerning
Change
in
Accounting
Method,
please
refer
to
IRM
4.10.13.
Additionally,
examiners
are
encouraged
to
consult
with
the
Change
in
Accounting
Method
(CAM)
Technical
Advisor
for
additional
assistance.
4.10.3.5.5
(03-01-2003)
Step
5:
Determination
of
the
Depth
of
the
Examination
of
the
Taxpayer’s
Books
and
Records
The
fifth
step
is
determining
the
depth
of
the
examination
of
the
taxpayer’s
books
and
records.
Factors
that
should
be
considered
when
determining
the
depth
include:
Type
of
Records
—
taxpayers
use
a
variety
of
bookkeeping
methods
and
maintain
different
types
of
records.
Volume
of
Records
—
voluminous
records
may
be
encountered
when
auditing
larger
taxpayers
or
when
the
taxpayers
records
are
unorganized.
Note:
When
a
taxpayer
submits
unorganized
records,
the
burden
is
on
the
taxpayer
to
organize
them
and
prepare
summaries
and
reconciliations.
This
can
be
done
with
or
without
the
examiner’s
presence.
The
depth
of
the
examination
of
the
taxpayer’s
books
and
records
should
be
established
after:
Interviewing
the
taxpayer,
Touring
the
business
site
(if
applicable),
and
Evaluating
the
taxpayer’s
internal
controls.
The
depth
may
be
expanded
or
contracted
as
the
examination
progresses,
if
warranted.
The
depth
of
the
examination
of
the
taxpayer’s
books
and
records
can
be
limited
to
the
verification
of
specific
items.
This
is
appropriate
for
Office
Audit
examinations
of
wage
earners
and
small
Schedule
C’s
(where
gross
receipts
have
not
been
classified
as
an
audit
issue).
The
depth
of
the
examination
of
the
taxpayer’s
books
and
records
should
include
sampling
techniques
when
there
are
voluminous
records.
This
is
an
effective
use
of
time
in
situations
when
it
is
impossible
to
review
all
records
.
Mechanical
verification
of
particular
accounts
or
journals
should
be
kept
to
a
minimum.
If
the
degree
of
error
is
substantial,
the
taxpayer
should
be
asked
to
make
suitable
verification
and
correction
before
the
examination
proceeds.
Mechanical
verification
of
the
taxpayer’s
books
and
records
should
be
more
extensive
when
indications
of
fraud
are
present.
Taxpayers
are
required
by
law
to
maintain
accounting
records
in
sufficient
detail
to
enable
the
preparation
of
an
accurate
tax
return
(IRC
section
6001)
.
The
appearance
of
the
records
is
not
important
as
long
as
the
accuracy
and
orderliness
are
not
affected.
If
the
taxpayer’s
records
are
lost,
destroyed,
or
are
not
available
due
to
circumstances
beyond
the
taxpayer’s
control,
examiners
may
allow
the
taxpayer
to
present
reconstructed
records.
The
reconstructed
records
should
be
reviewed
to
determine
the
amounts
are
ordinary
and
necessary
to
the
business
activity.
When
records
are
incomplete,
nonexistent,
or
suspect,
the
Examining
Officer’s
Activity
Record
(Form
9984)
should
document
all
attempts
to
obtain
the
taxpayer’s
records
and
the
group
manager
should
be
informed
so
delays
can
be
kept
to
a
minimum.
4.10.3.5.6
(03-01-2003)
Step
6:
Reconciling
the
Taxpayer’s
Books
and
Records
to
the
Tax
Return
The
sixth
step
is
reconciling
the
taxpayer’s
books
and
records
to
the
tax
return.
The
reconciliation
traces
the
process
the
taxpayer
used
to
prepare
the
return
from
the
books
and
records.
The
records
used
for
this
reconciliation
are:
Taxpayer
and/or
accountant
summaries,
reconciliations,
and
account
grouping
papers
—
These
will
show
the
grouping
of
book
accounts
to
the
respective
line
items
on
the
tax
return.
Profit
and
loss
statement
—
The
profit
and
loss
statement
is
a
financial
report
of
an
entity’s
revenues
and
expenses
for
the
accounting
period.
The
report
summarizes
the
net
income
or
net
loss
for
the
period.
The
report
is
sometimes
referred
to
as
a
"P&L
"
,
income
statement,
or
statement
of
operations.
Compilations,
audited
and
certified
financial
statements.
Trial
balance
sheets
—
The
trial
balance
is
the
listing
of
all
accounts
in
the
general
ledger
and
their
balances.
A
trial
balance
may
be
prepared
at
any
time.
Adjusted
trial
balance
—
A
trial
balance
taken
immediately
after
all
year-end
adjusting
entries
have
been
posted
is
called
an
adjusted
trial
balance.
The
adjusted
trial
balance
is
used
to
prepare
financial
statements.
The
balance
taken
immediately
after
closing
entries
have
been
posted
is
called
a
post-closing
trial
balance.
Schedule
M
adjustments
are
calculated
next,
and
then
the
tax
return
is
prepared.
Adjusting
journal
entries
—
Normally
a
taxpayer
will
need
to
correct,
adjust
or
reclassify
some
original
book
entries
by
making
adjusting
journal
entries.
The
adjusting
journal
entries
are
often
recommended
by
persons
conducting
the
year-end
audit
for
financial
reporting
purposes.
Tax
reconciliation
workpapers
—
The
trial
balances
and
adjusting
(and
consolidating,
if
applicable)
entries
are
usually
included
in
what
the
taxpayer
may
call
the
"tax
reconciliation
workpapers"
or
"grouping
papers"
.
The
tax
reconciliation
workpapers
are
requested
at
the
beginning
of
an
examination.
These
workpapers
include
the
final
balance
which
ties
the
tax
return
to
the
general
ledger
and
other
analyses
necessary
to
complete
the
return.
The
following
audit
techniques
should
be
used
to
reconcile
the
taxpayer's
books
and
records
to
the
tax
return:
Reconcile
the
profit
or
loss
shown
on
the
return
to
the
taxpayer’s
books.
Compare
prior
and
subsequent
years
P&L
statements.
Identify
significant
changes
and
adjust
the
scope/depth
of
the
examination
as
needed.
Review
the
adjusted
trial
balance,
including
the
adjusting
entries
and
explanations.
Compare
the
current
year’s
trial
balance
to
the
prior
and
subsequent
year’s
balance.
Note
significant
variations
for
further
inquiry.
Review
the
adjusting
journal
entries.
Analyze
the
adjusting
journal
entries
to
verify
the
corrections
or
reclassifications
are
proper.
Confirm
the
taxpayer’s
explanations
depict
the
true
effect
of
the
adjustments.
4.10.3.6
(03-01-2003)
Schedules
M–1
&
M–2
The
following
section
outlines
procedures
for
analyzing
Schedule
M–1
and
Schedule
M–2.
4.10.3.6.1
(03-01-2003)
Schedule
M–1
Schedule
M–1
is
a
critical
schedule
for
identifying
potential
tax
issues
resulting
from
both
temporary
and
permanent
differences
between
financial
and
tax
accounting.
For
a
corporation,
Schedule
M–1
is
the
reconciliation
between
net
income
per
the
books
and
taxable
income
before
the
net
operating
loss
deduction,
dividends
received,
and
the
special
deductions
per
Schedule
C.
For
a
partnership,
Schedule
M–1
is
the
reconciliation
of
net
income
per
the
books
to
the
net
income
per
Schedule
K
after
taking
into
consideration
all
the
separately
stated
income
and
expense
items.
Use
the
following
audit
techniques
to
examine
the
entries
on
Schedule
M–1.
Verify
that
net
income
per
the
books
agrees
with
net
income
per
Schedule
M–1,
line
1.
If
not,
obtain
the
taxpayer’s
reconciliation
of
net
income,
per
the
books
to
net
income,
per
Schedule
M–1,
line
1.
The
taxpayer
is
taking
the
Schedule
M–1
adjustments
off
the
return.
Obtain
the
workpapers
showing
how
all
Schedule
M–1
adjustments
were
calculated.
Verify
that
large
Schedule
M–1
adjustments
going
in
opposite
directions
(i.e.,
one
increasing
taxable
income
and
the
other
decreasing
taxable
income)
were
not
netted
to
arrive
at
what
appears
to
be
an
immaterial
amount
not
worthy
of
further
review.
Example
of
audit
techniques
—
Expense
on
return
&
not
books:
Abandonment
Loss
$(100,000)
Expense
on
books
&
not
return:
Workman
Compensation
Loss
$
101,000
Net
Schedule
M–1
Adjustment:
Expense
on
Books
&
not
return
$1,000
Review
legal
authority
supporting
book
vs.
tax
difference.
Compare
current
year
M–1
adjustments
to
prior
and
subsequent
years’
Schedule
M–1
adjustments:
If
a
prior
year’s
Schedule
M–1
adjustment
is
not
made
in
the
current
year,
determine
the
reason
why.
If
a
new
Schedule
M–1
adjustment
is
made
in
a
subsequent
year,
determine
if
a
similar
Schedule
M–1
adjustment
should
have
been
made
in
the
year
under
examination.
For
book
vs.
tax
temporary
timing
differences,
verify
that
the
applicable
Schedule
M–1
adjustments
were
made
on
the
prior
and
subsequent
year
returns.
Example:
During
1994,
the
taxpayer
received
$30,000
for
a
three
year
agreement
to
buy
a
specific
amount
of
raw
materials
from
a
supplier.
For
book
purposes
this
$30,000
will
be
amortized
into
income
at
$10,000
per
year
over
the
three
year
term
of
the
agreement.
For
tax
purposes,
the
$30,000
will
be
recognized
as
income
when
received
in
1994.
The
1995
tax
return
is
under
audit.
Review
the
1994
return
and
verify
the
Schedule
M–1
adjustment
(income
on
return
and
not
books
of
$20,000)
was
made.
The
following
Schedule
M–1
adjustments
should
have
been
made:
1994
M–1:
Income
on
return
and
not
books
$30,000
—
$10,000
=
$20,000
1995
M–1:
Income
on
books
&
not
return
($10,000)
1996
M–1:
Income
on
books
&
not
return
($10,000)
Reconcile
the
total
federal
income
tax
expense
per
the
books
(including
both
current
and
deferred
amounts)
to
the
federal
tax
Schedule
M–1
adjustment.
Investigate
any
differences.
Generally,
for
most
reserves,
a
schedule
should
be
prepared
showing
the
beginning
and
ending
balances.
If
the
reserve
increases
during
the
year,
a
Schedule
M–1
adjustment
should
have
been
made
to
increase
taxable
income.
If
the
reserve
decreases,
taxable
income
would
be
decreased
through
a
Schedule
M–1
adjustment.
4.10.3.6.2
(03-01-2003)
Schedule
M–2
Analyze
all
changes
in
the
retained
earnings
account
per
books
during
a
given
accounting
period.
Reconcile
income
per
books
with
income
per
return.
(Schedule
M–2,
line
2
equals
Schedule
M–1,
line
1.)
Reconcile
opening
balance
with
prior
year’s
ending
balance.
(Schedule
M–2,
lines
3,
5,
and
6.)
Verify
that
no
deduction
has
been
claimed
for
expenses
related
to
stock
dividends.
(Schedule
M–2,
line
5b
and
line
6.)
Determine
that
income
items
recorded
as
credits
have
been
properly
included
in
income.
Consider
imposition
of
IRC
section
531
tax.
Reconcile
ending
balance
to
book
balance.
Exhibit
4.10.3–4
is
an
example
of
a
reconciliation
of
income
and
analysis
of
unappropriated
retained
earnings.
4.10.3.7
(03-01-2003)
Bank
Record
Reconciliations
Bank
records
are
third
party
source
documents
which
support
the
taxpayer’s
records.
They
provide
an
audit
trail
for
transactions
not
disclosed
in
the
taxpayer’s
books
and
records.
An
examination
of
the
bank
records
is
necessary
to
determine:
whether
bank
account
transactions
are
being
properly
recorded;
whether
amounts
deposited
from
any
taxable
source
have
not
been
reported;
whether
any
improper
entries
were
recorded
during
the
year.
The
depth
of
the
bank
account
analysis
depends
on
the
circumstances
of
each
examination.
The
analysis
is
more
important
in
an
examination
where
the
records
are
inadequate,
nonexistent
or
possibly
falsified.
See
IRM
4.10.4
for
more
details.
4.10.3.7.1
(03-01-2003)
Step
1:
Review
of
Taxpayer’s
Bank
Account
Reconciliation
Review
the
year-end
bank
account
reconciliations
prepared
by
the
taxpayer
to
determine
how
much
audit
work
is
required.
If
the
bank
accounts
reconcile
back
to
the
books,
then
all
transactions
are
probably
recorded
somewhere
in
the
records.
The
transactions
should
be
tested
for
proper
recordation.
If
reconciliations
do
not
exist
or
the
bank
accounts
do
not
reconcile
to
the
books,
additional
audit
procedures
are
necessary.
Reviewing
the
bank
reconciliations
involves
the
following
steps:
Trace
the
ending
balance
to
the
general
ledger.
Review
any
outstanding
checks
and
investigate
their
status.
Review
outstanding
deposits
and
determine
if
all
are
included
in
the
reconciliation.
Trace
total
deposits
and
disbursements
per
the
reconciliation
to
the
general
ledger
account
entries.
4.10.3.7.2
(03-01-2003)
Step
2:
Review
of
Monthly
Bank
Statements
Review
the
monthly
bank
statements
to:
Gain
an
understanding
of
the
frequency
and
typical
amounts
of
deposits.
Determine
the
average
amount
and
volume
of
checks
written.
Establish
the
interaction
between
accounts.
Compare
the
total
deposits
to
the
gross
income
of
the
taxpayer
by
considering
non-taxable
deposit
sources
such
as
loans,
checks
to
cash,
transfers
between
accounts,
gifts
and
inheritances,
and
insurance
proceeds
and
by
identifying
large,
unusual,
questionable
(LUQ)
deposits
and
withdrawals
which
warrant
further
audit
action.
Keep
in
mind
that
this
is
not
a
bank
deposit
indirect
method
of
determining
income,
which
is
only
appropriate
for
cash
method
taxpayers
or
taxpayers
who
have
inadequate
books
and
records.
Trace
these
LUQ
items
through
the
ledger
to
determine
their
source
and
book
treatment.
Interview
the
appropriate
person
to
determine
the
treatment
of
LUQ
items.
4.10.3.7.3
(03-01-2003)
Step
3:
Bank
Deposit
Analysis
The
purpose
of
the
bank
deposit
analysis
is
to
determine
the
source
of
the
deposits.
An
analysis
is
time
consuming
and
in
many
instances
inappropriate,
as
in
the
case
of
a
large
corporation
with
a
double
entry
accounting
system.
Therefore,
the
examiner
must
use
judgment
as
to
the
extent
and
degree
of
this
analysis.
For
testing
the
reporting
of
income,
trace
specific
items
of
income
from
the
source
document
through
to
the
general
ledger
to
determine
whether
all
income
transactions
are
reported
properly
and
to
detect
unreported
or
improperly
recorded
items.
A
review
of
two
or
three
months’
transactions
postings
should
be
sufficient.
Large,
unusual
or
questionable
(LUQ)
deposits
deserve
attention.
Information
from
the
initial
interview
should
help
determine
what
is
LUQ.
Some
examples
of
LUQ
deposits
include:
A
large
deposit
when
the
normal
is
small,
Even
dollar
amounts
when
most
are
not
even,
Cash
deposit(s)
by
a
non-cash
business,
Regular
monthly
deposits
from
unidentified
source(s)
(possible
sources
include
unreported
rental
or
installment
sale
income,
and
repayment
of
loans
without
reporting
appropriate
interest
income),
Any
other
deviations
from
a
regular
deposit
pattern.
4.10.3.7.4
(03-01-2003)
Step
4:
Reconciliation
of
Bank
Deposits
to
Gross
Receipts
A
useful
audit
procedure
for
small
to
medium-size
taxpayers
who
deposit
the
majority
of
their
gross
receipts
into
a
bank
account
is
the
reconciliation
of
bank
deposits
to
gross
receipts
reported
on
the
tax
return.
Non-taxable
sources
of
income
are
critical
to
this
computation
and
should
be
identified
first.
If
the
deposit
analysis
shows
no
material
discrepancy
between
deposits
and
gross
receipts,
then
a
testing
of
income
transactions
may
be
all
that
is
needed
to
complete
the
examination
of
income.
See
IRM
4.10.4,
Material
Understatements
and
Managerial
Involvement
for
more
information.
If
the
deposit
analysis
shows
a
discrepancy
between
deposits
and
gross
receipts,
the
audit
steps
are
expanded
to
determine
the
cause
of
the
discrepancy.
See
4.10.4,
Audit
Techniques
for
In-Depth
Examinations
of
Income:
Corporations
and
Other
Business
Returns
for
more
information.
Exhibit
4.10.3–5
is
a
possible
format
for
reconciling
deposits
to
gross
receipts.
4.10.3.7.5
(03-01-2003)
Step
5:
Check
Analysis
A
check
analysis
is
conducted
as
a:
Means
of
verifying
the
expenses
and
deductions
claimed
on
the
return.
Source
of
information
to
determine
the
total
disbursements,
including
nondeductible
expenditures.
A
detailed
analysis
is
time
consuming
and
only
necessary
when
there
are
inadequate
records
or
when
a
potential
for
unreported
income
is
present.
If
a
review
of
the
check
disbursements
is
necessary,
a
quick
scan
of
the
cash
disbursements
journal
can
be
made.
Look
for
LUQ
items
and
follow
up
as
necessary.
Checks
should
be
analyzed
to
identify:
Possible
undisclosed
income,
Possible
investments,
Possible
expenditures,
Check
endorsements
When
there
are
inadequate
records
or
when
the
possibility
of
unreported
income
is
present,
an
indirect
method
of
determining
income
is
indicated.
IRM
4.10.4
contains
guidelines
and
computational
instructions
for
indirect
methods.
The
preliminary
analysis
of
corporation
and
partnership
returns
should
also
include
consideration
of
the
balance
sheet.
The
balance
sheet
analysis
is
a
useful
technique
to
review
the
taxpayer’s
financial
position
and
identify
adjustments
to
the
profit
and
loss
accounts.
4.10.3.8.1
(03-01-2003)
Balance
Sheet
Definitions
A
balance
sheet,
or
statement
of
financial
position,
presents
the
financial
position
of
a
business
entity
on
a
specific
date.
The
balance
sheet
provides
a
summary
of
the
following
elements:
Assets
—
the
financial
resources
the
entity
owns,
future
benefits
obtained
or
controlled
by
the
entity
as
result
of
past
transactions
or
events.
Liabilities
—
the
debts
the
entity
owes,
the
sacrifice
of
economic
benefit,
obligations
to
transfer
assets
or
provide
services
to
other
entities.
Equity
—
the
remaining
interest
in
the
assets
of
the
entity
after
deducting
its
liabilities.
The
equity
represents
the
ownership
interest.
A
balance
sheet
is
a
detailed
expression
of
the
equation:
Assets
=
Liabilities
+
Equity
Exhibit
4.10.3–6
demonstrates
how
transactions
are
posted
to
balance
sheet
and
income
statement
accounts.
The
first
step
when
analyzing
a
balance
sheet
is
to
determine
whether
the
taxpayer’s
balance
sheet
is
tax
based
or
book
based.
If
the
balance
sheet
is
tax
based,
account
balances
are
calculated
based
on
the
tax
treatment
of
various
income
and
expense
items,
as
opposed
to
the
book
treatment
of
these
items.
In
most
instances
where
the
balance
sheet
is
tax
based,
the
net
income
per
the
books
will
not
agree
to
Schedule
M–1,
line
1
per
the
tax
return.
This
means
that
all
Schedule
M–1
adjustments
have
not
been
disclosed.
For
example,
balances
on
the
tax
return
balance
sheet
do
not
agree
to
balances
per
books.
Small
differences
may
be
the
result
of
different
account
groupings
for
book
and
tax
purposes.
Use
the
following
audit
steps
if
the
balance
sheet
is
tax
based:
Verify
net
income
per
books
agrees
to
net
income
per
Schedule
M–1,
line
1.
If
it
does
not
reconcile,
obtain
a
schedule
from
the
taxpayer
reconciling
the
net
income
per
the
books
to
net
income
per
Schedule
M–1,
line
1.
Verify
total
assets
and
retained
earnings
per
tax
return
balance
sheet
agrees
to
total
assets
and
retained
earnings
per
books.
Any
differences
should
be
analyzed.
Determine
if
the
taxpayer’s
accounting
method
clearly
reflects
income
pursuant
to
IRC
446(c).
4.10.3.8.3
(03-01-2003)
Step
2:
Identify
Accounts
for
In-Depth
Analysis
The
second
step
when
analyzing
a
balance
sheet
is
to
identify
accounts
for
in-depth
analysis.
See
IRM
4.10.2,
LUQ’s
Defined.
The
analysis
will
include
review
of
the
books
and
records
and
consideration
of:
Accounts
with
unusual
titles,
Unusual
entries
within
accounts,
Accounts
with
large
numbers
of
adjusting
journal
entries,
and
Accounts
with
large
dollar
amount
entries
in
one
month
versus
other
months.
4.10.3.8.4
(03-01-2003)
Step
3:
In-Depth
Analysis
The
third
step
of
a
balance
sheet
analysis
is
the
in-depth
analysis
of
the
balance
sheet
accounts
selected
in
Step
2.
The
following
subsections
present
specific
techniques
for
analyzing
individual
balance
sheet
items.
See
Exhibit
4.10.3–7
for
additional
information.
4.10.3.8.4.1
(03-01-2003)
Cash
on
Hand
in
Bank
Verify
the
book
year-end
balance
reconciles
to
the
bank
statement
year-end
balances.
Review
reconciling
items
for
propriety
and
test
transactions
as
appropriate.
Review
cash
disbursements
journal
for
a
representative
period.
Note
any
missing
check
numbers,
checks
drawn
to
the
order
of
cash,
bearer,
etc.;
large
or
unusual
items;
and
determine
propriety
thereof,
through
a
comparison
with
vouchers,
journal
entries,
etc.
In
the
case
of
a
cash
basis
taxpayer,
ascertain
if
checks
were
written
and
recorded
which
were
issued
after
the
close
of
the
year
under
examination.
Consider
checks
issued
for
cashier’s
checks,
checks
payable
to
cash,
etc.,
where
the
payee
and
nature
are
not
clearly
shown.
Obtain
bank
statements
and
cancelled
checks
for
each
bank
account
for
one
or
more
months,
including
the
last
month
of
the
period
under
examination.
Compare
deposits
shown
by
the
bank
statement
against
entries
in
the
cash
book.
Note
year-end
bank
overdrafts
in
the
case
of
a
cash
basis
taxpayer.
This
may
indicate
expenses
which
are
unallowable
since
funds
were
not
available
for
payment.
Determine
if
any
checks
have
remained
outstanding
for
an
unreasonable
time.
This
may
indicate
improper
or
duplication
of
disbursements.
Old
outstanding
checks
possibly
could
be
restored
to
income.
Determine
whether
voided
checks
have
been
properly
handled.
For
a
period,
test
sample
check
endorsements
to
see
if
they
are
the
same
as
payee,
noting
any
endorsements
by
owner,
or
questionable
endorsements.
Review
cash
receipts
journal
for
items
not
associated
with
ordinary
business
sales,
such
as
sales
of
assets,
prepaid
income,
income
received
under
claim
of
right,
etc.
Investigate
entries
in
the
general
ledger
cash
account.
Look
for
unusual
items
which
do
not
originate
from
the
cash
receipts
or
disbursements
journals.
These
entries
may
indicate
unauthorized
withdrawals
or
expenditures,
sales
of
capital
assets,
omitted
sales,
undisclosed
bank
accounts,
etc.
Test
check
some
cash
sales
with
the
cash
receipts
journal
to
ascertain
if
they
have
been
correctly
recorded.
Also,
check
cash
sales
made
at
the
beginning
and
end
of
the
period
under
examination
to
determine
if
year-end
sales
have
been
recorded
in
the
proper
accounting
period.
Test
check
disbursements
from
petty
cash
to
determine
if
there
are
any
unallowable
items
included.
Scrutinize
cash
overages
and
shortages,
being
alert
to
irregularities
which
may
have
cleared
through
accounts.
Review
the
cash
on
hand
account
to
determine
if
there
are
any
credit
balances
during
the
period
under
examination.
This
may
indicate
unrecorded
receipts.
4.10.3.8.4.2
(03-01-2003)
Notes
and
Accounts
Receivable
Check
entries
in
the
general
ledger
control
accounts.
Look
for
unusual
items,
especially
those
which
do
not
originate
from
the
sales
or
cash
receipts
journals.
Obtain
a
detailed
schedule
of
the
notes
and
accounts
receivable
at
year-end
showing
the
customers
name,
invoices
outstanding,
and
the
balance
due.
Determine
if
the
documentation
agrees
with
the
ending
balance
per
books.
Investigate
any
identified
differences.
Review
detailed
schedules
of
receivables
for
credit
balances.
This
may
indicate
deposits,
advance
payments
or
overpayments
which