- 6 - income tax credit for 1996. As a result of filing the amended return, petitioners received a refund of tax in the amount of $3,030. Procedural Matters The examination of petitioners’ income tax liability for 1996 arose out of an examination of NHIL’s employment tax liability. During the examination, petitioners did not provide any information to respondent’s revenue agent and failed to produce bank records or documentation in support of their position. Petitioners informed Grey, who represented petitioners during the audit, that the records were missing or were not in their possession. The notice of deficiency was sent to petitioners on July 13, 2000, shortly prior to expiration of the period of limitations. Third-party records received pursuant to summonses for various bank accounts were received by the IRS subsequent to the notice of deficiency and disclosed additional bank deposit income. Respondent then amended his answer to allege an increased deficiency, addition to tax, and penalty. On July 12, 2001, petitioners answered respondent’s interrogatories and request for admissions. The interrogatories specifically asked petitioners to identify any nontaxable sources of the deposits made into the Nationwide account, the Cohen account, or the NHIL account. Petitioners responded that theyPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 Next
Last modified: May 25, 2011