- 11 - the gift was $21,365, and that the value of the gift at the date of transfer was also $21,365. Later that month, on January 22, 1996, petitioner submitted a Federal income tax return (Form 1040) for 1993, which was executed by Mr. Magness on petitioner’s behalf. The return reflected a loss from the sale of petitioner’s interests in the Barrington Park and Southmark/Envicon limited partnerships that respondent had disallowed for 1986. On February 27, 1996, respondent’s Problem Resolution Office sent Mr. Peterson a letter regarding petitioner’s amended income tax returns for 1985 and 1986. The letter included an itemization of the documents and information that were needed in order to process the amended returns. The letter also stated, in part, as follows: The over-riding problem throughout the examination report centers around Mr. Hawksley’s failure to keep any kind of contemporaneous record of his business expenses. Another problem is that Mr. Hawksley’s employer provided a copy of a reimbursement policy, which indicated he could have been reimbursed for certain travel, entertainment, and moving expenses, had he applied for same in advance. The examiner’s conclusion * * * that all of Mr. Hawksley’s documentation lost validity and confidence was based on a two-fold observation: 1) The documentation provided during the course of the examination was apparently not what was used to prepare the original return, as there were large discrepancies between amounts presented to our examiner and those reported on the return; AND 2) Taxpayer’s inability to provide substantiation for one entire expense item--Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011