- 4 - in December 1987 at their residence. She began the audit by examining petitioners' bank deposits in order to identify possible unreported income. Ms. Bellamy examined deposit slips, petitioner's business records, and the records of some of the vendors with whom petitioner dealt. Ms. Bellamy discovered that substantial amounts of income were omitted from, and deductions were improperly claimed on, petitioners' 1984, 1985, and 1986 income tax returns. Petitioner's Brown Books During their first meeting, Ms. Bellamy questioned petitioner about his business books and records; he told her that there were no books to examine. Subsequently, petitioner provided her with bank statements, canceled checks, a bag of invoices, and sheets of notebook paper containing unexplained figures. In point of fact, petitioner used "brown books" to record income and profit, and to compile summary sheets of his Field Masonry business activities. The brown books were also used to calculate the amount of petitioners' annual charitable contributions. One of respondent's special agents accompanied Ms. Bellamy to petitioners' home for a second meeting regarding possible criminal violations. At that time, petitioner provided the agents with one of his brown books from a year prior to the years under consideration and showed them how he computed his income. Petitioner told them that the brown books and summary sheets forPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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