Roger L. and Patricia A. Lavallee - Page 7

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            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.                                                        



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