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During the year in issue, Mr. Brown operated a tree stumping
business, in which he removed tree stumps from the ground in
Mississippi and transported them to Brunswick, Georgia, to be
processed by Hercules, Inc. (Hercules), which paid him for the
stump wood that he delivered. In his business, Mr. Brown used at
least three Caterpillar tractors, two loaders, two trucks with
trailers, and two pickup trucks. Mrs. Brown maintained
petitioners' books and records, including those pertaining to Mr.
Brown's tree stumping business, and stored the records in
petitioners' house.
Mr. Brown maintained a shop in Fruitdale, Alabama, where he
repaired his tree stumping equipment. For more difficult repair
jobs, Mr. Brown sent his equipment to a garage in Richland.
Mr. Brown also served as pastor to a small church in
Mississippi. In his ministry, Mr. Brown, inter alia,
evangelized, visited people in hospitals, and attended wakes.
During September 1994, Willie Sue Daniels, a tax auditor
with respondent, met with Mrs. Brown to examine petitioners' 1991
return. At the meeting, Mrs. Brown produced substantiation for
certain deductions that petitioners had claimed on their return.
In order to complete the audit, Ms. Daniels scheduled a second
meeting, which Mrs. Brown missed because she was out of town
attending a funeral. On or around September 28, 1994, respondent
issued petitioners an initial report stating that their 1991
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