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1993 tax years. He did not, however, notify petitioners that
they were being audited for 1992 and 1993 and did not request
records from them relating to these years. During the audit, he
obtained information returns (i.e., Forms 1099) indicating that
petitioners had received income in 1992 as follows:
Albert R. Cujas, Jr.
Payor Type of Payment Amount
Maultsby Orthopedic Clinic PA Compensation $1,867
St. John Neuromuscular Therapy Seminars Compensation 13,214
Matol Botanical International Ltd. Compensation 630
State of N.C. Health Plan Compensation 2,302
Hartford Life Insurance Co. Compensation 677
State Employees Credit Union IRA distribution 25,623
State Employees Credit Union Interest 493
Susan W. Cujas
Payor Type of Payment Amount
Northwest Child Development Council, Inc. Compensation $4,702
The Investment Company of America Dividends 95
State Employees Credit Union Interest 114
State Employees Credit Union IRA distribution 10,973
Capital Guardian Trust Co. IRA distribution 4,902
After receiving this information, Agent Gardner contacted some of
the payors and obtained written verification of the items.
Agent Gardner did not obtain any evidence that petitioners
received income relating to 1993. He proceeded to reconstruct
petitioners' income for that year using data published by the
Bureau of Labor Statistics (BLS) and determined that each
petitioner incurred personal living expenses and received self-
employment income of $21,339. He also determined that: (1) For
1992, petitioners were each liable for a 10-percent additional
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