Robin F. and Anne F. Jenkins - Page 5

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            the years under consideration had been destroyed because he had                            
            given them to his children to color on.  He also expressed his                             
            belief that records more than 3 years old should be destroyed.                             
                  Because of the possible criminal violations, petitioners                             
            retained a lawyer.  Their lawyer had possession of the brown books                         
            for the years under consideration.  The brown books were ultimately                        
            turned over to respondent's special agent who provided them to Ms.                         
            Bellamy.                                                                                   
            Tax Return Preparation                                                                     
                  Petitioner prepared petitioners' tax returns for the years                           
            under consideration.  Mrs. Jenkins did not participate in the                              
            completion of the returns.  Petitioners paid no income tax for                             
            1982, 1983, 1985, and 1986; they paid $240 in income tax for 1984.                         
                  Ms. Bellamy primarily used the bank deposit analysis (and then                       
            made modifications as additional information was provided) to                              
            identify petitioners' unreported Schedule C income for 1984, 1985,                         
            and 1986.  Petitioner did not report all of his gross receipts from                        
            his Field Masonry business.                                                                
                  When the audit began, petitioner wrote a $25,000 personal                            
            check, payable to the Internal Revenue Service, and gave it to Ms.                         
            Bellamy because he was certain that petitioners had underreported                          
            their income and owed at least that amount.                                                
                  a.  1984 Joint Federal Income Tax Return                                             
                  Petitioners claimed, among others, the following expenses as                         
            Schedule C deductions on their 1984 return:                                                




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