Jeffrey L. Beecroft and Carol Larkin-Beecroft - Page 5

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                    ordinary and necessary to your business, we have disallowed the                                                                                        
                    amount shown."                                                                                                                                         
                              On February 3, 1995, respondent sent a 30-day letter to                                                                                      
                    petitioners proposing that petitioners were liable for a $14,939                                                                                       
                    deficiency in 1993 income tax and a $2,988 penalty under section                                                                                       
                    6662(a).4  Respondent issued the subject notice of deficiency on                                                                                       
                    April 20, 1995, reflecting her determination of a deficiency and                                                                                       
                    penalty in the same amounts as proposed in the 30-day letter.                                                                                          
                    The deficiency and penalty shown in the notice of deficiency are                                                                                       
                    primarily due to the adjustments mentioned above.  Before the                                                                                          
                    notice of deficiency was issued, petitioners did not present                                                                                           
                    respondent with any substantiation for the disallowed deductions                                                                                       
                    or any explanation concerning the fact that the $21,025 of wages                                                                                       
                    shown on the Form W-2 from EP Management Services, Inc., was not                                                                                       
                    includable in their 1993 gross income.                                                                                                                 
                              On June 12, 1995, petitioners' counsel, Stuart S. Lipton,                                                                                    
                    mailed a letter to an Internal Revenue employee at an Internal                                                                                         
                    Revenue office in Los Angeles, California.  This letter states:                                                                                        
                              Dear Patty:                                                                                                                                  
                                        This is to confirm that there will be a meeting in                                                                                 
                              Room 4336 in the offices of the IRS at 300 North Los                                                                                         
                              Angeles Street at 12:45 p.m. on June 27, 1995, at which                                                                                      
                              Charles Thiras, accountant for the taxpayer, will                                                                                            
                              present documentary evidence to support the validity of                                                                                      


                              4 Petitioners claim that this 30-day letter was the first                                                                                    
                    notice that they received alerting them that respondent was                                                                                            
                    auditing their 1993 Federal income tax return.                                                                                                         




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