- NEXTRECORD -
Respondent's Examination of Petitioner's 1991 Return
Respondent's examination of petitioner's 1991 income tax
return began in 1993.
During the course of the examination, petitioner represented
that he maintained a wall calendar at the barber shop that he
used to keep track of appointments and to record income, but that
the current month of the calendar was not retained after month's
end.
During the course of the examination, petitioner also
represented that he maintained a small, red, spiral notebook in
which he contemporaneously summarized his income on a daily
basis. Petitioner produced the notebook for the examining agent
and, at trial, introduced 3 pages from it (petitioner's exhibit).
Petitioner's exhibit indicates that petitioner worked
throughout 1991 on Tuesdays, Wednesdays, and Fridays, but never
on any other day of the week. It also indicates that for the
first 11 months of the year, petitioner worked every Tuesday,
every Wednesday, and every Friday, except for Friday, November
22, 1991. For that date, the word "off" appears immediately
above what appears to be a dollar entry, which has been
4(...continued)
reported self-employment tax, petitioner's return essentially
disclosed a loss of $1,686; i.e., $1,400 + 1/2($572). In
revising petitioner's taxable income for deficiency purposes,
respondent reduced the aggregate amount of adjustments made to
petitioner's income in the notice of deficiency by the $1,686
loss.
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