- 55 - 6, 1996, that is not disclosed by the record, revenue agent Powell received petitioners’ 1995 joint return from the Internal Revenue Service Center in Cincinnati, Ohio. Revenue agent Powell reviewed that return and compared it with petitioners’ 1994 joint return. That comparison disclosed to revenue agent Powell that in the 1995 joint return there were: (1) A significant decrease from 1994 to 1995 in the gross receipts that petitioners reported in the respective Schedules C of petitioners’ 1994 joint return and 1995 joint return, (2) an ending inventory for Barbara’s Gift Shop for 1994 of $442,197 and an ending inventory for that business for 1995 of $0, and (3) an increase from 1994 to 1995 in the expenses that petitioners claimed in the respective Schedules C of petitioners’ 1994 joint return and 1995 joint return. As a result, revenue agent Powell formally commenced an examination of petitioners’ 1995 joint return. Although revenue agent Powell became aware through the CID report of certain employment tax issues involving Barbara’s Gift Shop and Sandbar Wholesale Trust, he concluded that that informa- tion did not affect his examination of petitioners’ 1994 and 1995 joint returns, and he did not make any inquiries of petitioners regarding Sandbar Wholesale Trust during his examination of those joint returns. Nor did petitioners allude to Sandbar Wholesale Trust or to any purported transfer of the two businesses to that trust during that examination.Page: Previous 45 46 47 48 49 50 51 52 53 54 55 56 57 58 59 60 61 62 63 64 Next
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