- 16 - for $220 in 1990 and $1,760 in 1992, which were not deducted by virtue of travel and entertainment statutory limitations in effect for those years. In 1991, WVI capitalized $137,410 in animal trophy collection expenses and deducted $104,175. The remaining $913 was not deducted because of the travel and entertainment statutory limitations. WVI’s and Petitioners’ Audits for 1989-92 In July 1991, Revenue Agent Richard Puchaty audited WVI’s tax returns. Petitioners’ tax returns were included in the audit after Revenue Agent Puchaty noticed an unusual pattern of recording expenses relating to the animal trophy collection across four different accounts in the company’s general ledger. Revenue Agent Puchaty concluded that in light of continual mischaracterization of the animal trophy accounts throughout the company’s ledger, as well as his difficulty in locating the animal trophy expenses entries, these expenses were intentionally being hidden. In an effort to clarify WVI’s ledger system, Revenue Agent Puchaty sought an interview with both Dr. Gow and Ms. Lee; his request was denied. Petitioners’ 1989-92 Tax Returns On their 1989 and 1990 returns, petitioners reported the values of the stock awarded to Dr. Gow as $40,000 and $20,000, respectively. They did not seek an expert valuation of the stock before reporting the aforementioned values on their tax returns. Petitioners reported no dividend income for 1989 and 1990, andPage: Previous 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 Next
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