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Petitioners’ joint 1992 Federal income tax return was filed
on April 19, 1995, their 1993 return was filed on April 16, 1996,
and their 1994 return was filed on April 16, 1997. Petitioner
prepared each of these returns. Items reported on the Schedules
C are summarized as follows:
Year Gross Income Total expenses Profit/(Loss)
1992 $28,850 $46,719 ($17,869)
1993 29,500 46,505 (17,005)
1994 24,500 45,318 (20,818)
Items reported on the Schedules E are summarized as follows:
Year Rents received Total expenses Income/(Loss)
1992 $85,820 $151,975 ($66,155)
1993 101,968 140,733 (38,765)
1994 128,216 120,482 7,734
The examination of petitioners’ returns began in March
1996.1 Petitioner failed to provide the revenue agent with all
of the documents that she requested from him. As best can be
determined from the record, the revenue agent did not issue any
summonses to petitioners or third parties. Business account bank
statements and canceled checks were provided to the revenue
agent, as was petitioner’s check register for the business
account. Petitioner also provided a check register for the joint
account, but the register included only entries made from April
through December 1992. The revenue agent concluded that
petitioners’ income could not be determined from the books and
1 Sec. 7491 is therefore inapplicable.
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