- 3 - or another complete records did not exist at the time of the audit and that reconstructions of petitioners’ income and expenses had to be made. The reconstructions to a large extent were based upon petitioners’ checks and deposit tickets from the years in issue. The examining agent also relied upon bank records and summary documents prepared by petitioners’ accountant. The primary issues discussed by the parties prior to the issuance of the notice of deficiency were cost of goods sold, gross receipts, and the sale of oil royalties. The third issue, sale of oil royalties, was resolved in petitioners’ favor prior to the issuance of the notice of deficiency. Because petitioners believed they would owe no taxes if the first issue, cost of goods sold, were decided in their favor, petitioners in settlement negotiations agreed to concede all other issues if respondent made a favorable determination regarding the cost of goods sold amounts. Respondent issued a statutory notice of deficiency to petitioners dated May 19, 1998. The notice set forth the following adjustments: 1992 1993 1994 Advertising expense ($14,725) -0- -0- Aircraft expense -0- -0- ($14,186) Commission expense -0- $31,000 -0- Cost of goods sold 219,038 (2,204) 289,491 Depreciation expense (471) (902) (832) Gross receipts (16,808) 5,113 (200,250)Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 Next
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