- 3 - 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 1991Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 Next
Last modified: May 25, 2011