- 5 - The Oakland boutique closed its doors in 1994. Another boutique, which Special Occasions had opened in Baton Rouge, Louisiana, in 1994, closed in 1997. At the time of trial, petitioner was employed by the Internal Revenue Service (IRS) as an acting Appeals officer. Petitioner has been employed by the IRS since 1974 and has worked at different times as a tax auditor, revenue agent, and technical analyst. Petitioner was told by her supervisors at the IRS that she could not maintain the books and records of Special Occasions, Special O, or Klyce "as a condition of [her] employment with the IRS". The books and records of Special Occasions, Special O, and Klyce were maintained by Linda Klyce. Although petitioner did not maintain the books and records of either Special Occasions or Special O, petitioner wrote most of the checks drawn from Special Occasions and Special O's shared checking account at Wells Fargo Bank. Petitioner reported nonpassive losses from Special O on Schedules E of her Federal income tax returns in the amounts of $6,875,4 $8,345, and $13,777 for the 1991, 1992, and 1993 tax years, respectively. Petitioner also reported nonpassive losses 4 Though petitioner reported 1991 losses from Special O in the amount of $6,875 on her Federal income tax return, the parties stipulated 1991 losses from Special O in the amount of $6,895.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011