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Technical and Miscellaneous Revenue Act of 1988, Pub. L. 100-647,
102 Stat. 3342, 3743-3746. Rule references are to the Tax Court
Rules of Practice and Procedure.
Background
A. Petitioners
Leon Spear (the decedent) and Jeannette Spear (Mrs. Spear)
lived in Philadelphia, Pennsylvania, when they filed their
petition. They operated parking lot businesses from 1956 through
the years in issue and dealt extensively in cash.
The decedent and Mrs. Spear kept cash in safe deposit boxes
and entered their safe deposit boxes many times from 1972 to
1977. They destroyed the records of their cash receipts from
their parking lot businesses, including daily settlement sheets,
before respondent's audit.
B. Respondent's Investigations of the Decedent and Mrs. Spear
Respondent's agents interviewed the decedent and Mrs. Spear
and sent document requests to them before respondent issued the
notice of deficiency. Respondent interviewed the decedent and
Mrs. Spear's Federal income tax preparer and a bookkeeper for
their corporations. Respondent summoned third parties, reviewed
public records, and examined the decedent and Mrs. Spear's bank
accounts and financial statements.
On December 9, 1977, Revenue Agent Michael McGuckin
(McGuckin) asked the decedent and Mrs. Spear how much cash they
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