George H. and Evelyn G. Cooper - Page 6

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            Evelyn Cooper.  Petitioner admitted that this travel was not                                 
            related to his work for Con Tex, Inc.  In addition, a ticket for                             
            travel in February 1987 submitted by petitioner does not relate                              
            to petitioner's work for Con Tex, Inc., since he did not even                                
            begin such work until July 1987.  Therefore, petitioner's records                            
            were not precise, as he maintains, and are not reliable.                                     
                  Furthermore, despite petitioner's mischaracterized                                     
            meticulous record keeping, the various summaries he prepared from                            
            his records each set forth a different amount of his alleged                                 
            expenses.                                                                                    
                  For example, a spreadsheet allegedly prepared by petitioner                            
            to assist his return preparer with the preparation of                                        
            petitioners' 1987 tax return purports to show that petitioner                                
            incurred expenses of $37,382 relating to his work with Con Tex,                              
            Inc. (this summary also purports to show that petitioner was                                 
            reimbursed $31,992 for such expenses).                                                       
                  By contrast, a summary of expenses prepared by petitioner,                             
            and presented to the examining agent in this case, states that                               
            petitioner incurred business expenses totaling $43,579 relating                              
            to his work with Con Tex, Inc., during the 1987 tax year.                                    
                  A third summary purporting to show the expenses incurred by                            
            petitioner, and which allegedly takes into account amounts set                               
            forth on documents included within several exhibits prepared by                              







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