- 3 - During the years in issue, petitioners, as sole proprietors, owned and operated an apartment rental business in the Salt Lake City metropolitan area. Petitioners owned seven apartment complexes consisting of a total of 482 rental units. Petitioners generally shared responsibility for operating the apartment rental business and for maintaining and managing the apartments. Petitioners did not keep formal books and records with regard to their apartment rental business, nor did petitioners hire a bookkeeper or accountant to maintain any books and records. The only records that petitioners maintained of income relating to their apartment rental business consisted of reports from apartment managers. The only records that petitioners maintained of expenses relating to their apartment rental business consisted of canceled checks and copies of bills. Apparently, petitioners maintained no journals or ledgers relating to their apartment rental business. On each of March 4, September 29, September 30, and December 30, 1983, petitioners purchased from various banks a certificate of deposit, each in the amount of $100,000. For 1982 and 1983, petitioners prepared for their income tax return preparer handwritten summaries with respect to rental income and expenses relating to petitioners' apartment rental business. On the summary sheets, petitioners' rental income and most expenses for each year were indicated using the sevenPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011