Dan S. and Nancy J. Mitchell - Page 5

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          Petitioners’ Forms 1040 for 1989, 1990, and 1991 were                       
          prepared using the cash basis method of accounting.  Prior to               
          December 1993, an examination of petitioners’ returns was                   
          commenced by the Internal Revenue Service.  In December 1993,               
          petitioners filed a Form 1040X, Amended U.S. Individual Income              
          Tax Return, for 1990.  In September 1994, petitioners filed a               
          Form 1040X for 1989 and a second Form 1040X for 1990.  The                  
          statutory notice of deficiency for 1990 and 1991 was sent to                
          petitioners on September 29, 1994.  In December 1994, petitioners           
          filed a third Form 1040X for 1990 and a Form 1040X for 1991.  On            
          each of the amended Forms 1040X, petitioners claimed farm losses            
          on Schedule F and recharacterized the interest and tax expenses             
          claimed on Schedule A as farm loss expenses, claimed the standard           
          deduction instead of itemized deductions on Schedule A, and                 
          purportedly changed from cash to accrual accounting for farm                
          operations allegedly begun in 1989.  They claimed depreciation of           
          unidentified farm equipment in the amount of $3,000 on the                  
          amended returns for 1990 and 1991.  They then claimed a net                 
          operating loss carried forward from 1989 to 1990 and 1991.                  
               During the course of the bankruptcy proceeding, petitioners            
          returned to the vendors certain office equipment that had been              
          possessed by Mitchell & Associates pursuant to lease/purchase               
          agreements.  Rent and lease expense deductions for office                   
          equipment of Mitchell & Associates were claimed on Schedules C              
          for 1990 and 1991 in the amounts of $7,800 and $5,600,                      




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