Alber I. and Georgette H. Said - Page 4

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          Schedule C reporting gross receipts of $3,615,300, cost of goods            
          sold of $3,392,128, expenses of $208,380, and a net profit of               
          $16,912 that was reported on their Form 1040.                               
          Respondent’s Examination                                                    
               Revenue Agent Emmanuel Pascual (Pascual) audited                       
          petitioners’ returns for all 3 years.  Respondent’s standard                
          procedure when examining a sole proprietorship engaged in                   
          operating a gasoline station involves a field visit of the                  
          proprietor’s home and business.  Pascual drove by Mena’s and by             
          petitioners’ home prior to contacting petitioners regarding the             
          examination of their returns.  Pascual observed that petitioners            
          resided in a two-story home with a three-car garage and that                
          petitioner drove a Mercedes-Benz.                                           
               During the examination, petitioners consistently postponed             
          scheduled interviews and appointments with Pascual.  Pascual                
          requested from petitioners documentation regarding their income,            
          expenses, and cost of goods sold for Mena’s.  Petitioners did not           
          provide complete bank records, and Pascual issued summonses to              
          obtain copies of petitioners’ personal and business bank                    
          statements, canceled checks, and deposit slips.  At one point,              
          petitioners’ representative told Pascual that petitioners had no            
          personal bank accounts.  Pascual found that petitioners did have            
          both business and personal bank accounts, and he obtained copies            
          of bank statements, canceled checks, and deposit slips.  Pascual            






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