Robert and Ella M. Tolbert - Page 3

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               1.  Phillip H. and Susan M. Hecht                                      
               2.  Government of the District of Columbia                             
               3.  Bryant Street, N.W.                                                
               4.  I Street, S.E.                                                     
               5.  K Street, N.W.                                                     
               6.  Capital Cab, 1033 3rd Street                                       
               7.  Southern Baptist Church, 134 L Street                              
          The Hecht job was not completed until sometime during 1990.                 
          Petitioner received cash payments for jobs performed at Bryant              
          Street, N.W.; I Street, S.E.; and K Street, N.W.                            
               Petitioners reported $232,349.35 as gross receipts on their            
          1989 Schedule C.  The amount reported was derived from a schedule           
          generated by petitioners' tax return preparer, David Richardson             
          (Richardson).  Richardson generated the schedule based on                   
          conversations with petitioner and on limited bank statements                
          provided to Richardson by petitioner.                                       
               In November 1993, during the course of the examination of              
          their 1989, 1990, and 1991 returns, petitioners submitted a                 
          Form 1040X, Amended U.S. Individual Income Tax Return, for 1989             
          indicating $197,433.78 in gross receipts.  The Form 1040X                   
          computed gross receipts based solely on bank deposits and                   
          included no gross receipts from cash transactions.                          
               Petitioners were not members of any specific church during             
          1989, 1990, or 1991.  Instead, petitioners attended from time to            
          time one of three or four different churches.  Petitioners made             
          cash contributions when they attended church.  Petitioners did              
          not receive and did not request a record of their contributions             
          from any of the churches that they attended.                                




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