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cash receipts journal for that year. Mr. Dennett and Ms. Wildes
used those materials to reconstruct another 1987 return for
petitioners that was not filed (reconstructed 1987 return). The
amount of gross receipts reflected in Schedule C of petitioners'
reconstructed 1987 return was virtually identical to (1) the
amount of gross receipts reflected in the cash receipts journal
for 1987 and (2) the amount of gross receipts reflected in
Schedule C of the return that petitioners filed for that year.
On September 26, 1989, the day after the September 1989
meeting, Mr. Kaply submitted Form 4564, Information Document
Request (IDR), to Mr. Dennett requesting the information that he
had requested at that meeting, as well as additional information
with respect to certain of the written materials that petitioners
had provided to him at that meeting. In the IDR, Mr. Kaply
requested, inter alia, the following: (1) Information with
respect to the Indian Head personal checking account, including
the source of the funds deposited into that account, and (2) an
explanation of the source of the money deposited into petition-
ers' savings accounts. Approximately one month after sending the
IDR to Mr. Dennett, Mr. Kaply had not received any information
with respect to those two inquiries, and he decided to summons
petitioners' records from Indian Head, Kennebunk, and Hampton Co-
operative Bank.12 Thereafter, when Mr. Kaply learned of the
12 The record does not contain information with respect to what
(continued...)
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