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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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