- 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