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memorandum on July 29, 1992, with respect to petitioners' Form
656.
In a letter dated November 23, 1992, Mr. Conner informed
respondent of petitioners' disagreement with the rejection of
their Form 656 and the limited extent of Revenue Agent Lovell's
proposed adjustments. Mr. Conner's letter included eight
attachments which provided substantiation for several of the
deductions discussed therein. With the exception of three
documents, petitioners had not previously provided this
information to respondent during her examination of their
returns.
In his letter, Mr. Conner proposed the following adjustments
to petitioners' Schedule C deductions:
1985
Per Per
Office Auditor Barrow Appeal
Adjustment
Depreciation $11,831 $11,957 ($126)
Repairs 10,275 10,275 0
Travel & entertainment 4,676 8,218 (3,542)
Claims/chargebacks 697 697 0
Interest on truck loans 0 5,473 (5,473)
All other expenses 50,474 50,474 0
Total $77,953 $87,094 ($9,141)
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