- 24 - possession, he gave it to Ms. Davis. Despite three separate requests for investment accounts, Ms. Davis discovered one of the investment accounts herself when she was reviewing certain canceled checks. On one of these checks, she saw the name "Shearson Lehman". When asked about the investment accounts, Mr. Bruno told her there was an investment account with Shearson. He further stated that he believed all of the money in the Shearson account represented transfers from petitioner's checking account. This categorization of the Shearson deposits as transfers from the checking account was significant because, if accurate, they would have represented nontaxable income already considered as income by Ms. Davis in her review of the account. Petitioners' 1987 income tax return did show interest received from Shearson. Ms. Davis did not receive an IRP document, which is a document internally processed by the Service and lists interest income, capital gains, et cetera, reported to the Service. However, neither the interest amount reported on the return nor the IRP document would have provided or given access to the detailed statements. Without these detailed statements, Ms. Davis would not have been able to determine whether income had been deposited or withdrawn from that account, and whether the interest income or capital gains were earned from moneys placed in the account 10 years before or during the same year.Page: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011