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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.
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