- 6 - goods sold of $18,742, and business expenses totaling $10,996, resulting in a net loss of $8,886. In computing cost of goods sold, petitioners reported $1,500 opening inventory, $18,742 purchases, and $1,500 ending inventory. Respondent’s Examination and Determinations On July 16, 1998, Carol had her first meeting with respondent’s examining agent, Susan Leary (Leary), regarding petitioners’ 1995 Federal income tax return. At this initial meeting, Leary asked Carol a number of routine background questions, including but not limited to questions about petitioners’ ages and education levels, and about their savings and investments. Leary also requested sales records relating to Columbia. At the initial meeting, Carol gave Leary no indication where the sales records might be. Carol and Leary met on two subsequent occasions in August 1998. At the subsequent meetings, Carol informed Leary that the Columbia sales records had been lost. By notice of deficiency dated January 6, 2000, respondent determined a $6,125 deficiency in petitioners’ 1995 Federal income tax. As part of this determination, respondent reduced petitioners’ claimed Schedule C expenses by $7,212, as follows: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