- 5 - petitioner received in 1987 was in repayment of loans she had made to Mr. Sharer during that year. Petitioner failed to file timely her income tax return for 1986. Her 1986 return was filed on October 18, 1988. By letter dated November 16, 1990, the Internal Revenue Service (IRS) informed petitioner that her 1986 and 1987 returns had been selected for examination. In the letter, an audit appointment was scheduled for December 12, 1990, and attached to the letter was an Information Document Request (IDR), requesting that petitioner provide certain information, which included bank records, documentation on her income from taxable and nontaxable sources, and returns and other tax statements concerning petitioner's investment in the partnership from which she claimed partnership loss deductions for 1986 and 1987. Petitioner did not provide the requested information to the IRS. On January 17, 1991, the IRS sent another letter and a second IDR, this time to petitioner's attorney. The second IDR requested essentially the same information and documentation that had been sought by the first IDR. The second IDR also asked for promissory notes and records on loans that petitioner made from 1986 through 1988. Petitioner again did not provide the requested records. As a result, the IRS summonsed bank records, obtained a copy of the partnership agreement of the partnership in which petitioner claimed loss deductions for 1986 and 1987 from the Sacramento Recorder's Office, and obtained a copy ofPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011