- 6 - proprietorship for each of the years at issue: Year Gross Receipts 1995 $449,283.08 1996 330,646.69 1997 339,646.51 On January 9, 1996, respondent sent petitioner a letter (respondent’s first notice of inadequate records) notifying him that he was not keeping adequate records with respect to peti- tioner’s sole proprietorship, as required by the Code, which would enable him to report accurately, and respondent to verify accurately, petitioner’s tax liability.5 Respondent’s first notice of inadequate records directed petitioner to send respon- dent within six months an explanation (required explanation) of how petitioner had corrected his recordkeeping in order to meet the requirements of the Code. On July 22, 1996, respondent sent petitioner a letter (respondent’s second notice of inadequate records) informing petitioner that respondent had not received from him the required explanation.6 Respondent’s second notice of inadequate records directed petitioner to notify respondent within 15 days about the steps that he had taken to correct the recordkeeping problems described in respondent’s first notice of inadequate records. 5Respondent’s first notice of inadequate records did not indicate the year or years to which that notice pertained. 6Respondent’s second notice of inadequate records indicated that it pertained to petitioner’s taxable years 1991, 1992, and 1993.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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