Jack R. and Patricia J. Finnegan - Page 5

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          in connection with their construction and attempted sale of the             
          Acapulco house (the real estate activity).4                                 
               In April 1994, the Internal Revenue Service (IRS) assigned             
          petitioners' refund claim to Office Auditor Monte Kruse (Mr.                
          Kruse).  On or about May 20, 1994, Mr. Kruse proposed a partial             
          disallowance of the refund claim.  On or about June 23, 1994, Mr.           
          Kruse sent petitioners a Letter 905 (Formal Notice of Partial               
          Claim Disallowance) which allowed $10,801 of the refund claim.              
          Petitioners protested the proposed partial disallowance, and on             
          June 30, 1994, the case was referred to the Appeals Office.                 
               On July 5, 1994, $10,801 of the tax was abated.  On or about           
          July 25, 1994, the examination division notified petitioners that           
          $10,801 would be refunded.                                                  



               3(...continued)                                                        
                    Item                                Amount                        
                    Advertising                        $1,719.83                      
                    Commissions and Fees               125.00                         
                    Repairs and Maintenance            85.00                          
                    Supplies                           4,405.99                       
                    Utilities                          921.08                         
                    Mortgage Interest                  49,860.47                      
                    Total                              57,117.37                      
          Petitioners concede any difference between the new or increased             
          amounts and the amounts respondent concedes.                                
               4  We use the term "real estate activity" for convenience              
          only.                                                                       





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