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Schedules B and E, even though he reported on the Form 1040 that
he had income from interest and royalties. Of the items on the
Schedule C, eight are shown as estimates.
On his 1985 tax return, petitioner's Schedules D and E
(although attached to the tax return), are uninformative, and, of
the Schedule C items, two are shown as estimates.
On his 1986 tax return, petitioner's Schedule E is similarly
uninformative, and, of the Schedule C items, two are shown as
estimates.
For about 3 years, Douglas J. Juergens (hereinafter
sometimes referred to as Juergens), an attorney, shared office
and storage space with petitioner in Norman. In or about January
1988, after petitioner had prepared his tax returns for 1982
through 1986, Juergens moved from the shared space. At that
time, Juergens had his office equipment, legal files, and
miscellaneous records removed from the shared storage space and
transported to storage space at Juergens' sister's barn. Some of
petitioner's records were inadvertently moved together with
Juergens' materials. In or about January 1990, Juergens'
sister's barn was destroyed by fire.
Petitioner had two interviews with Burns, both at Burns'
office. At the first interview, on June 13, 1989, before the
barn fire but after Juergens' move, petitioner brought three
boxes of unsorted records relating to 1981 through 1987. Burns
briefly looked at these materials, and asked petitioner, in
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