Greg McIntosh and Sheila R. McIntosh - Page 7

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          petitioners's cousin and his wife, Keith and Renee McIntosh.  In            
          addition, petitioners provided verification for property taxes              
          paid in 1995 and legal and professional fees paid in 1996.                  
               The enclosures further included a copy of an escrow                    
          statement dated August 30, 1994, from the Fidelity National Title           
          Insurance Company of California (Fidelity National) for "PROPERTY           
          ADDRESS:  AP #007-060-04" crediting petitioners with a deposit of           
          $11,104.67 (the same amount as the "US Bank" check mentioned                
          above).  Petitioners also enclosed a copy of a handwritten                  
          receipt to petitioners from Fidelity National dated August 29,              
          1994, in the amount of $11,104.67, naming "US Bank" as "maker".             
          The items were submitted as verification of a portion of the cost           
          of goods sold claimed on the Schedules C for 1996.                          
               The petition in this case was filed on September 16, 1999.             
          The Court filed respondent's answer on October 26, 1999.                    
          Mr. Brown faxed additional information to the IRS Office of                 
          Appeals (Appeals) on November 11, 1999.  The information was                
          related to petitioners' 1994 tax year.  Mr. Brown settled the               
          1994 tax issues with the IRS, and he considered the "auto,                  
          property taxes, and insurance" issues to be "carryover" issues              
          from the settlement to 1996.                                                
               In a letter to Mr. Brown dated November 17, 1999, Appeals              
          requested additional information about the settlement of the                
          1994 "carryover" adjustments and additional information to verify           
          insurance and interest expenses.  Appeals also requested                    

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