Robin F. and Anne F. Jenkins - Page 4

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            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 for                           




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