- 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011