- 12 - their return for each such year. With respect to the Schedule C car and truck expenses, for each of the years at issue, petitioners provided their return preparer with the amount of business miles that they claimed they had driven during each such year, and that return preparer used the standard mileage rate to determine the amount of the deduc- tion for such expenses that petitioners claimed in Schedule C of their return for each such year. In Schedule E for 1993, 1994, and 1995, petitioners reported rental income from the Toledo rental property of $4,000, $5,318, and $7,397, respectively, and rental expenses from that property of $6,668, $6,330, and $10,239, respectively. In the notice, respondent used an indirect method, the so- called source and applications of funds method, in order to determine whether petitioners had unreported Schedule C gross receipts for any of the years at issue. That was because peti- tioners had not maintained adequate records for any of those years. Respondent derived all of the amounts that respondent used in applying the source and application of funds method with respect to each of the years at issue from one or more of the following sources: Petitioners’ joint return for each such year, petitioners’ bank statements for each such year, petitioners’ monthly listings for each such year, and petitioners’ oral statements made to respondent’s revenue agent who conducted thePage: Previous 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 Next
Last modified: May 25, 2011