Estate of Frank Johnson - Page 92




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          $6,250, and $7,849, respectively.  Respondent allowed them a                
          $7,310 self-employment tax deduction for 1990.  For each of the             
          years 1983 through 1986, respondent also allowed Frank and                  
          Katherine a $3,000 married couples deduction.                               
                    2.  Larry’s Audit and Notice of Deficiency                        
               Agent Combs met with Larry, Nancy, and Baptiste in February            
          1991 regarding the audit of Larry and Nancy’s 1988 return.  He              
          subsequently expanded the audit to include their returns for                
          earlier and later years as well as the returns of Frank and                 
          Katherine, Ronnie, and Sylvia.  Larry and Nancy initially                   
          provided information to Agent Combs relating to amounts claimed             
          on their returns.  Subsequently, they refused Agent Combs’                  
          requests for additional information and for an extension of the             
          statute of limitations for the 1987 return.  Larry and Baptiste             
          refused to cooperate further in the audit on the advice of                  
          counsel because they believed that Agent Combs was prejudiced               
          against Gypsies and had referred, or intended to refer, their               
          returns to the IRS Criminal Investigation Division.                         
               During 1994, respondent made a jeopardy assessment against             
          Larry and Nancy after Agent Combs received information from the             
          Daytona Beach Shores police department that both Larry and his              
          daughter Sylvia had obtained driver’s licenses issued in false              
          names and had opened safe deposit boxes under those names into              
          which they were transferring moneys from other safe deposit                 






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