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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 petitioners
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