- 4 - items in the ledger appeared to be nondeductible and/or personal in nature. Petitioner was reluctant to provide any information beyond what was contained in the ledger on the ground that, since the items appeared in a ledger, they were necessarily correct and further verification should be unnecessary. Petitioners would not sign a Form 872 to extend the statute of limitations, and the case was forwarded for the issuance of a statutory notice of deficiency. The notice of deficiency was mailed to petitioners on December 12, 1996. The petition, consisting of seventy-seven (77) paragraphs, most of which alleged "evidentiary facts", was filed on March 7, 1997. Respondent's answer was filed on March 31, 1997. By letter dated June 20, 1997, to petitioners' attorney, David P. Leeper, respondent's appeals officer informed Mr. Leeper as follows: Dear Mr. Leeper: I have reviewed the examiner's workpapers that were prepared in connection with the examination of the Millers' tax returns for 1993. Based on these workpapers, many of the expenses disallowed were for lack of substantiation by the taxpayer. The following information is need [sic] to help resolve these issues at our scheduled appeals conference: 1. A list of the recipients of the various statuettes deducted as advertising expense. This list should include the location and approximate dates the items were placed.Page: Previous 1 2 3 4 5 6 7 8 9 Next
Last modified: May 25, 2011