Samuel T. Seawright and Carol A. Seawright - Page 6




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          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:             











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