- 3 - Petitioner maintained two bank accounts at Amerifirst Bank (Amerifirst), one in his name and one in his son’s name, and petitioner maintained one bank account at Commercial Bank & Trust Co. (Commercial Bank) in his name. Petitioner generally deposited commissions and fees received in his loan brokerage business into these bank accounts. In connection with preparation of his 1986 Federal income tax return, petitioner submitted to his tax return preparer a letter dated February 21, 1987, in which petitioner indicated that he received in 1986 only $10,482 in total commissions and fees from his loan brokerage business. This total commission and fee income of $10,482, along with net income of $2,227, and zero taxable income, were reported on petitioner’s 1986 Federal income tax return. On March 15, 1988, respondent's revenue agent began an audit of petitioner's 1986 Federal income tax return. During the audit, petitioner did not keep scheduled appointments with respondent’s revenue agent, and petitioner provided only limited records to the revenue agent with regard to his loan brokerage business. On April 20, 1988, as a result of his inability to meet with petitioner and petitioner's general lack of cooperation, respondent’s revenue agent proposed audit adjustments against petitioner in which the revenue agent disallowed $8,332 in various claimed business expenses and proposed the negligencePage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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