- 20 - $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 depositPage: Previous 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 Next
Last modified: May 25, 2011