Robert T. and Mary F. Gow - Page 16




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          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, and                






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