Gerald H. Evans - Page 3




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          Subsequently, but before the filing of the petition herein,                 
          petitioner and Linda Evans were divorced.                                   
               During 1981 through 1983, petitioner owned a corporation               
          known as G.H. Evans & Company (Evans & Co.).  In 1984, respondent           
          commenced an examination of Evans & Co. for its taxable years               
          1981 through 1983 through a revenue agent named Robert M. Coar              
          (Agent Coar).  During the corporate examination, Agent Coar                 
          determined that petitioner had received interest-free use of                
          corporate funds.  Based on this determination, Agent Coar                   
          extended the examination to include petitioner's joint income tax           
          returns for the taxable years 1981 through 1983.  Petitioner's              
          accountant, Eric Lear, represented petitioner during the                    
          examination.                                                                
               At the conclusion of the examination, Agent Coar made                  
          several income adjustments to petitioner's 1981 and 1982 taxable            
          years.  The adjustments for the 1982 taxable year were for                  
          unreported dividends from two sources (Evans & Co. and an                   
          unrelated payor) and additional wage income from an unrelated               
          source.  In a conversation with his supervisor, Agent Coar stated           
          that these adjustments gave rise to the total tax liability                 
          attributable to petitioner's individual examination.                        
               Petitioner agreed to Agent Coar's adjustments and in March             
          1985 executed Form 4549, Income Tax Examination Changes.  An                
          Agent of respondent executed the form during the following month.           





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