Stephen H. Rifkin & Pamela T. Rifkin - Page 3

                                        - 3 -                                         
          and in 1991 began an interior design business that she named                
          “Metamorphosis Design Group” (Metamorphosis).  During the 1992              
          and 1993 taxable years, Mrs. Rifkin owned and operated                      
          Metamorphosis from her residence, where she designed one-of-a-              
          kind furniture, lighting, and other interior decorating items.              
               Mr. Rifkin was disabled and unemployed throughout 1993, but            
          assisted Mrs. Rifkin by handling the paperwork and financial                
          matters for Metamorphosis.  No formal books or records were                 
          maintained for Metamorphosis, and Mr. Rifkin prepared                       
          petitioners' 1993 Federal income tax return, reporting certain              
          amounts as Metamorphosis' business income on Schedule C.  Mrs.              
          Rifkin signed the 1993 return without reviewing the contents.  On           
          their 1993 Schedule C, petitioners reported gross receipts of               
          $82,387, cost of goods sold of $32,453, and gross income of                 
          $49,934.                                                                    
               Rose Koczergo was assigned to audit petitioners' 1992 and              
          1993 income tax returns.  At the time of the trial in this case,            
          she had been an internal revenue agent for 4 years and a tax                
          auditor for the first 5 of her 9 years with the Internal Revenue            
          Service.  Prior to working for respondent, she held various                 
          positions in financial banking institutions.  Agent Koczergo                
          received a degree in accounting, but is not licensed as a public            
          or certified public accountant.                                             








Page:  Previous  1  2  3  4  5  6  7  8  9  10  11  12  13  14  15  16  Next

Last modified: May 25, 2011