Clifford F. Asher - Page 7

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               On his Federal income tax return for 1990, petitioner                  
          reported income from two sole proprietorships (Sungate Travel and           
          Sungate Tours located on Alcosta Boulevard in San Ramon,                    
          California), in addition to his wages from the corporation.  He             
          reported gross receipts of $1,649,088 from Sungate Travel and               
          $115,982 from Sungate Tours.  On his 1991 return, he reported               
          gross receipts of $1,090,975 from Sungate Travel and he reported            
          the sale of Sungate Tours.                                                  
               During 1993 and 1994, an agent of the Internal Revenue                 
          Service conducted an audit of the corporation's returns for the             
          taxable years ending May 31, 1991 and 1992, and petitioner's                
          individual returns for taxable years 1990 and 1991.  Petitioner's           
          accountant was present at all meetings with petitioner and the              
          agent.  The agent reviewed documents such as invoices and                   
          contracts supporting the corporation's depreciation schedule of             
          items related to the construction and furnishings of the loft.              
          The documents showed the purchase of a leather sofa and chair,              
          kitchen cabinets, fixtures for the bathroom, and blinds.                    
               During the course of the audit, the agent visited the office           
          building twice, once in July 1993 and again in July 1994.  While            
          walking down the hallway in the loft during the second visit, the           
          agent noticed a mattress with box spring and a cabinet in one of            
          the rooms.                                                                  







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