Shane Michael Optical, Co. - Page 3




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               The Shanes are husband and wife, and they own all the stock            
          of Shane Michael, a C corporation.  At the time of trial, Mr.               
          Shane was 81 years old. Shane Michael retails and wholesales                
          optical merchandise, and its business requires that its                     
          salespersons travel frequently and worldwide.  Shane Michael                
          generally requires that its salespersons pay their travel,                  
          entertainment, and other business expenses out of pocket and seek           
          reimbursement from it for those expenses.                                   
               Shane Michael and the Shanes use the same accounting firm to           
          perform their accounting and tax work, and they have used this              
          firm in each of the past 52 years.  As relevant herein, the                 
          accounting firm reviews Shane Michael's records and prepares its            
          financial statements and income tax returns.  A bank/lender                 
          requires that the firm "review" Shane Michael's records every               
          year.  The firm also prepares the Shanes' personal income tax               
          returns.  Each year, Mr. Shane places his tax records in a desk             
          drawer and, when tax time comes around, gives those documents to            
          the accounting firm to prepare his personal tax returns.  Mr.               
          Shane relies on the firm to prepare his personal and corporate              
          income tax returns correctly.                                               
               Shane Michael's tax returns for the subject years claim                
          deductions totaling $1,697,206, $1,446,621, and $1,544,323,                 
          respectively.  Of those amounts, respondent determined that Shane           
          Michael could not deduct the following amounts claimed for                  
          travel, automobile, and insurance expenses because it lacked                
          substantiation:                                                             


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Last modified: May 25, 2011