Marvin L. Barmes and Barbara J. Barmes - Page 55




                                       - 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

Last modified: May 25, 2011