Robin F. and Anne F. Jenkins - Page 3

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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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