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together with the exhibits thereto, are incorporated herein by
this reference.
Petitioner resided in Rogers, Arkansas, at the time that the
petition was filed with the Court.
A. Examination of Petitioner’s 1985 Return
On July 14, 1986, petitioner filed his Federal income tax
return, Form 1040, U.S. Individual Income Tax Return, for 1985.
On the return, petitioner listed his address as in Santa Barbara,
California. Petitioner attached to his return a Schedule C,
Profit or Loss From Business or Profession. On the Schedule C,
petitioner claimed total deductions in the amount of $36,145.
Approximately a year later, on July 10, 1987, respondent
sent a letter to petitioner, notifying him that his 1985 return
had been selected for examination and requesting him to furnish
all documentation used in the preparation of that return.
On August 7, 1987, petitioner sent respondent a reply
letter, requesting that the examination of his 1985 return be
transferred to respondent’s office in Modesto, California.
Respondent agreed to petitioner’s request, and on October 19,
1987, a revenue agent from the Modesto office sent petitioner a
letter requesting specific documentation pertaining to the
examination of petitioner’s 1985 return.
On November 20, 1987, Robert C. Davis (Mr. Davis), a
certified public accountant and petitioner’s representative under
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