- 7 - doubt as to any liability". The Form 656 proposed a reduction in petitioners' Federal income tax deficiencies for 1985, 1986, and 1987 in the amounts of $870, $2,987, and $4,104, respectively.7 Revenue Agent Kim Lovell was assigned to review petitioners' Form 656. In a telephone conference on May 7, 1992, Revenue Agent Lovell informed Mr. Conner that petitioners needed to present additional information if their case was to be closed. On May 11, 1992, Revenue Agent Lovell and Mr. Conner met to review additional documentation and to determine the extent of any adjustments to petitioners' Federal income tax liabilities for 1985, 1986, or 1987. In a Form 4549, which was proposed by Revenue Agent Lovell and dated July 29, 1992, she determined that petitioners were entitled to additional Schedule C deductions for 1985 and 1987 in the amounts of $430 and $621, respectively.8 This resulted in a reduction of petitioners' Federal income taxes for 1985, 1986, and 1987 in the amounts of $123, $2,9 and $166, respectively. Revenue Agent Lovell prepared a rejection 7These amounts were the same as the reductions in Federal income tax liability listed by petitioners on their amended returns. 8Revenue Agent Lovell increased petitioners' Schedule C deduction in 1985 by $430 to reflect petitioners' payment of a highway use tax. For 1987, Revenue Agent Lovell increased petitioners' Schedule C deductions for car/truck expenses, travel and entertainment expenses, and uniforms in the amounts of $127, $56, and $438, respectively. 9This $2 reduction in petitioners' Federal income tax liability for 1986 resulted from respondent's determination that petitioners were entitled to use income averaging in computing their tax liability for that year.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011