- 3 - FINDINGS OF FACT Some of the facts have been stipulated and are so found. The stipulation of facts and the attached exhibits are incorporated herein by this reference. Background Petitioners, husband and wife, resided in Sterling, Virginia, at the time they filed their petition. They timely filed joint Federal income tax returns for 1984, 1985, and 1986, the years under consideration. Respondent mailed petitioners a notice of deficiency with respect to all years under consideration on August 26, 1993. Robin F. Jenkins (hereinafter referred to in the singular as petitioner) obtained a high school diploma and completed one year of college. While in college, petitioner studied wildlife biology; he did not take any tax or accounting courses. He left college and became a mason by trade. During the years under consideration, petitioner was self-employed; he owned and operated a business known as Field Masonry. Anne F. Jenkins (Mrs. Jenkins) also graduated from high school and completed one semester of college study. She did not take any tax or accounting classes. Audit Respondent's revenue agent, Kathleen Bellamy (Ms. Bellamy), was assigned to audit petitioners' Federal income tax returns for the years under consideration. Ms. Bellamy first met petitionersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011