- 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