Robert E. and Carloyn S. Holmes - Page 24

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             sort of feed, and several salt licks in or around the                    
             wooded areas.  After he toured the property, Mr. Przytulski              
             asked Mr. Jackson, petitioners' accountant, for invoices                 
             and receipts to support petitioners' canceled checks.  In                
             response, Mr. Jackson offered Mr. Przytulski a disorganized              
             assortment of documents.  Although Mr. Przytulski asked                  
             Mr. Jackson to organize the documents, he never received                 
             the documentation he requested in an organized format.                   
                  In April 1992, Revenue Agent Robert Cole visited                    
             petitioners' property in conjunction with his audit of                   
             their 1989 through 1991 returns.  After touring the                      
             property, Mr. Cole asked Mr. Jackson to produce documents                
             to support petitioners' deductions during those years.                   
             Once again, Mr. Jackson offered Mr. Cole a box of                        
             disorganized records which included documents relating to                
             all of petitioners' checking accounts, including their                   
             personal accounts.  Petitioners never provided Mr. Cole                  
             with a summary reconciling their tax return entries with                 
             the documents they produced.                                             

                                       OPINION                                        
             Section 183                                                              
                  The primary factual issue in this case is whether                   
             petitioners' farming activity was an "activity not engaged               






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