Frank de Bane and Kathleen Naber-de Bane - Page 7

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          accounts, I could not find $15 which could qualify for a bad debt           
          and I do not have recollection of why I put $15 on that tax                 
          return.”  With respect to the advertising expenses of $140, the             
          summary lists charges of $5.90 at Kmart, $122.13 at Home Depot,             
          $5.94 at Wal-Mart, and $5.94 at Raley’s.  Petitioner could not              
          explain how these charges were related to advertising, even                 
          though he prepared the summary listing them as such in                      
          preparation for trial.  Similarly, with respect to the commission           
          and fee expenses, the summary lists charges made at Chevron,                
          Scandinavian Design (for furniture), Wal-Mart, Student Book                 
          Exchange, and Jo-Ann Fabrics, along with the annual credit card             
          fee of $100.                                                                
               Finally, certain amounts reported by petitioners on the                
          return raise suspicion.  For example, petitioners reported                  
          exactly 85 percent business and 15 percent personal use with                
          respect to both the Ford Ranger and the computer.  Petitioners              
          also reported bad debt expenses of $15 and business property                
          rental expenses of $62.  All of these amounts seem to have been             
          arbitrarily selected by petitioners when filing their tax return.           
               Petitioners argue that IRS employees had possession of their           
          “tax receipts” and refused to return them.  They provide no                 
          reliable evidentiary support for this contention.  In letters               
          petitioner sent to the IRS in late 1999 and early 2000, he                  
          referred to the existence of missing records which had been given           

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