- 8 - disallowed the claimed charitable contribution deduction3 and child care credit. Respondent did not process the amended return, and it was not considered at the time respondent prepared the notice of deficiency. Sometime in 1991 or 1992, the Criminal Investigation Division of the Internal Revenue Service (IRS) began an investigation of Morris. On March 27, 1992, a search warrant was issued authorizing a search of Morris' office for various items. Pursuant to the search warrant, investigators were authorized to seize, among other things, Federal income tax returns or amended returns for the years 1989, 1990, and 1991 which included Schedule A itemized deductions or Schedule C business losses; amended Federal income tax returns for 1990, 1991, and 1992; and client lists or other records identifying clients. The search warrant was executed on March 30, 1992. The return on the search warrant reflects that 84 boxes of documents were seized, including 3 boxes which contained information related to petitioners. These boxes were identified as "Brown, Craig--Tax records and return", "Craig & Debbie Brown financial records", and "Amended return, Brown". Subsequently, Special Agent Steven Boyd returned to petitioners all of their identified documents which were seized pursuant to the execution of the search warrant. 3 The remaining itemized deductions were less than the standard deduction, so respondent disallowed them and allowed petitioners the standard deduction.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
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