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Petitioner’s Books and Records
Relating to His Horse Activity
and His Cattle Activity
During the years at issue, petitioner did not maintain a
separate bank account for either his horse activity or his cattle
activity. During those years, petitioner retained invoices,
receipts, and canceled checks relating to the expenses that were
incurred in those activities.7 However, he did not maintain
books or records such as ledgers and registers to memorialize the
various transactions relating to those activities or to maintain
a historical record of those activities (e.g., the dates on which
horses were purchased, foals and calves were born, and calves
were sold; the specific nature of any training that the horses
that he owned received; and the specific periods during which any
such training was provided).
Petitioner's Tax Returns
For the years 1988 through 1991, petitioner, who has a
limited knowledge of the Federal income tax laws and who has not
had any formal training in accounting or tax matters, retained
the services of Mr. McVeigh, a tax return preparer since about
1982, to prepare his individual Federal income tax returns
(returns).
Petitioner relied on Mr. McVeigh to prepare requests to
extend the time within which to file his returns for 1989 and
7 Those invoices, receipts, and canceled checks are not part of
the record in this case.
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