- 7 - 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.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011