Linda Klyce - Page 5




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          entitled to larger expense deductions than the amounts allowed by           
          respondent.                                                                 
               During the years at issue, Special Occasions and Special O             
          shared the same bank account, titled in the name of Special                 
          Occasions.  The partners of Special Occasions and the                       
          shareholders of Special O failed to keep accurate books and                 
          records of the income and expenses of the two entities.  This               
          problem was compounded by the fact that not only the entities               
          used the same bank account but also that the books and records              
          failed to properly track the deposits and expenditures of each              
          separate entity.                                                            
               Klyce Day Care did not file partnership information returns            
          for the tax years 1987 through 1993.  Special Occasions did not             
          file partnership returns for the tax years 1987 through 1991 but            
          filed returns for 1992 and 1993.  Special O filed Forms 1120S,              
          U.S. Income Tax Return for an S Corporation, for 1991, 1992, and            
          1993.                                                                       
               Petitioner did not file individual Federal income tax                  
          returns for 1988, 1989, and 1990.  However, in the stipulations             
          referenced earlier, petitioner and respondent agreed to                     
          petitioner's income and certain other related items for these               
          years, leaving at issue only those items discussed hereafter.               
          Petitioner's taxable income for these years, respectively, was              







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