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receipts of $7,160 on her 1989 return.3 In addition, Gold
Country paid petitioner an automobile allowance during each of
the years at issue (1988 and 1989). This automobile allowance
was determined by respondent to constitute income for the 2 years
in question.
By letter dated November 16, 1990, the Internal Revenue
Service (IRS) informed petitioner that her 1986, 1987, and 1988
income tax 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 and information on nontaxable sources
of income. 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. Petitioner again
did not provide the requested records. As a result, the IRS
summonsed petitioner's bank for information. The IRS was unable
to get copies of all of petitioner's bank records, such as copies
of all checks deposited and all checks written.
A notice of deficiency for 1988 was issued on August 11,
1992. In that notice, respondent determined net income
3
Petitioner listed the name of her Schedule C business as
"Mary Lee Sharer".
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