10
G. Petitioners' U.S. Tax Returns
1. Petitioners' Tax Return Preparer
Michael Perkins (Perkins), a certified public accountant in
Raleigh, prepared petitioners' tax returns for tax years 1989 to
1993. Perkins and petitioner-husband have been friends for more
than 10 years. Their sons played soccer together. Perkins and
his son accompanied petitioner-husband on the soccer team's trip
to Brazil in 1990.
Perkins reviewed some receipts for earlier years to ensure
that petitioner-husband complied with U.S. tax requirements for
deducting business and travel expenses, but he primarily relied
on the worksheets furnished by petitioner-husband. At trial,
Perkins did not remember whether he saw sales receipts, invoices,
journals, or ledgers for International for the years in issue.
2. Petitioner-Wife's Import Business
Petitioner-wife's import sales business had gross receipts
of $4,900 in 1990. Petitioners included that amount in the gross
receipts reported on petitioner-husband's Schedule C for
International for 1990. Petitioners did not file a separate
Schedule C for petitioner-wife's import sales business with their
original 1990 return. Petitioners reallocated $4,900 from
petitioner-husband's International business to petitioner-wife's
Schedule C attached to their amended return for 1990.
Petitioner-wife had costs of goods sold and expenses totaling
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011