Oliver E. Stubblefield - Page 9

                                   - 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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