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On September 9, 1997, as part of his examination of Levitz,
respondent's examining agent requested petitioner's account
transcript for the year in issue. The transcript, known to
respondent as a writ-view (RTVUE), was ordered by the examining
agent to determine whether petitioner had filed a 1994 tax
return. The RTVUE is a summary of petitioner's individual tax
return and the various attached schedules.3 The RTVUE showed
that petitioner had filed a 1994 tax return with respondent on
October 15, 1995.
The examining agent examined the RTVUE for large, unusual,
or questionable items. The RTVUE showed that petitioner had: (1)
reported business income in the amount of $232,216; (2) claimed
itemized deductions in the amount of $23,404; (3) claimed capital
losses in the amount of $3,000; (4) claimed net operating losses
in the amount of $1,795,146; and (4) claimed Schedule E losses in
the amount of $973,006. The examining agent determined that the
net operating loss deductions and Schedule E losses were
questionable and requested the petitioner's 1994 income tax
return from respondent's service center on September 29, 1997.4
3
A RTVUE is a record of line items from Forms 1040, 1040A,
and 1040EZ and their accompanying schedules. The RTVUE is
created as the returns are processed at the service center.
4
For whatever reasons, the examining agent never received the
original of petitioner's 1994 income tax return from the service
center.
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