Pramod and Raj Tandon - Page 3

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          proper disposition of petitioners' motion.  Rule 232(a)(2).  We             
          therefore decide the matter before us based on the record that              
          has been developed to date.                                                 
          Background                                                                  
               Petitioners are husband and wife and resided in Kenner,                
          Louisiana, at the time that their petition was filed with the               
          Court.  Petitioners moved to the United States from India in                
          1979.                                                                       
               Petitioners filed their Federal income tax returns for 1991            
          and 1992 in August 1993 and January 1994, respectively.                     
          Petitioners filed Federal income tax returns for 1991 and 1992              
          for RAJ International of Louisiana, Inc. (RAJ), petitioners'                
          solely owned and controlled "S" corporation, in March 1992 and              
          January 1994, respectively.  Petitioners failed to file any                 
          Federal income tax returns for the years 1987 through 1990.                 
          Respondent initiated an examination of petitioners' and                     
          RAJ's tax returns for the taxable years 1991 and 1992.  Revenue             
          Agent Bacino was assigned to both these examinations.                       
               RAJ was in the business of selling women's clothing,                   
          jewelry, and accessories through a store in Metairie, Louisiana,            
          and at various trade shows held throughout the country.  RAJ                
          conducted a substantial portion of its business activity in cash.           
               Revenue Agent Bacino determined that RAJ's books and records           
          were inadequate and incomplete and that they failed to reflect              
          accurately RAJ's financial activity.  RAJ's income tax preparer             




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