- 10 - Petitioners never did file an amended return. Petitioners did not consult a certified public accountant or a tax attorney with respect to the tax treatment of the income from Sanrio and losses from Regent. However, they did ask an accountant about the extent of their mortgage interest deduction and about amending their return to claim an additional deduction. E. The Audit Process Richard Clement (Clement) is respondent's revenue agent responsible for the audit of petitioners' 1990 Federal income tax return. He is familiar with real estate practices in the San Francisco Bay area and has conducted audits of companies engaged in real estate transactions. In July of 1994, Clement examined the Federal income tax return filed by Sanrio. While auditing this return, he noticed Sanrio's $840,000 payment by wire transfer to Susanna's account at BNP. Accordingly, he requested an RTVUE, which is a computer- generated document showing certain types of information from a tax return (such as gross receipts reported on a Schedule C). Using the RTVUE, Clement discovered that the Paus had reported gross receipts on their 1990 Schedules C in an amount less than the $840,000 transfer reflected on Sanrio's return. After reviewing the Paus' 1990 return, Clement decided to audit it. He selected for examination gross receipts and expenses from the Schedules C, and Schedule A deductions for home mortgage interest and contributions. Clement left severalPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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