- 3 -
FINDINGS OF FACT
Petitioners were notified by letter dated October 20, 1997,
addressed to their accountant, William Brown, that their Federal
income tax returns for 1995 and 1996 were to be examined by the
Internal Revenue Service (IRS). At the same time, the IRS issued
a Form 4564, Information Document Request (IDR), related to those
years' returns. Petitioners' Federal income tax return for 1994
was already under examination by the IRS, and some of the
information listed in the IDR of October 20, 1997, relates to tax
year 1994.
The IDR was directed at obtaining books and records
concerning petitioners' home-building income and expenses for
1994 through 1996 reported on Schedules C, Profit or Loss From
Business; underlying documentation of various Schedule C items;
business and personal bank statements and canceled checks for
1993 through January 31, 1997; and documentation for the sale of
a personal residence and for real estate taxes for 1996.
On April 16, 1998, the IRS issued another IDR requesting
essentially the same information except with more specificity for
certain Schedule C items.
On June 4, 1998, the examining agent met with Mr. Brown and
Greg McIntosh (petitioner). At the meeting petitioner discussed
his wage activities and his Schedules C activity. Petitioner was
employed as a dispatcher from March 1993 through July 1995 and
was unemployed between July 1995 and May 1996. Between May and
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