Robert E. and Carloyn S. Holmes - Page 23

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             activities, record the bill on a ledger, and write a check               
             to pay the amount due.  Petitioners introduced one page of               
             their 1987 ledger and all pages of their 1988 ledger into                
             evidence.  There is no documentary evidence in the record                
             of petitioners' bookkeeping practices for the remainder of               
             1987 or any portion of 1989 through 1991.                                
                  Petitioners conceded at trial that check No. 1004                   
             drawn on RC's Chemical account and made payable to Chapman               
             Nursery & Landscaping in the amount of $2,250, which was                 
             entered into their 1987 cash disbursements journal as a                  
             "farm expense", was actually a personal expense incurred                 
             for landscaping around their house.  Petitioners also                    
             conceded that check Nos. 1134 and 1215 drawn on RC's                     
             Chemical account and made payable to Brian Minto in the                  
             amounts of $455.68 and $309.62, respectively, which were                 
             entered in petitioners' ledger as farm expenses for 1988,                
             were actually used to pay personal expenses.                             

             Respondent's Examination                                                 
                  In May 1990, Revenue Agent Paul Przytulski visited                  
             petitioners' property in conjunction with his audit of                   
             their 1987 and 1988 returns.  During this visit,                         
             Mr. Przytulski noticed many deer tracks on the property,                 
             several wooden boxes near the ponds which contained some                 






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