- 4 - addition to tax. Petitioner did not agree to these proposed adjustments to his 1986 Federal income tax return. After respondent’s revenue agent proposed the above adjustments, petitioner submitted to respondent portions of a bank statement relating to the Amerifirst account that was in petitioner's name. Petitioner did not provide to respondent’s revenue agent bank statements relating to the other two bank accounts. In the summer of 1988, after petitioner rejected the above proposed audit adjustments for 1986, respondent’s revenue agent mailed to petitioner a second letter in which the revenue agent reasserted the initial adjustments and addition to tax and proposed to disallow an additional $846 in claimed business expenses. Again, petitioner refused to agree to respondent's proposed adjustments. On November 10, 1988, in response to a summons from respondent’s revenue agent, petitioner and petitioner's attorney met with respondent’s revenue agent. During this meeting, petitioner provided respondent’s revenue agent with a schedule on which petitioner indicated that he received $26,806 in total commissions and fees in 1986. At this meeting, petitioner acknowledged the second bank account at Amerifirst in his son's name, but petitioner did not acknowledge that he also maintained the bank account at Commercial Bank. The November 10, 1988,Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
Last modified: May 25, 2011