- 4 -
not submit any documents pertaining to Mr. Eberhardt's medical
expenses or any of the other documents requested in the IDR.
On March 10, 1998, respondent sent petitioners a second IDR
regarding petitioners' medical expenses, casualty or theft loss,
and Schedule C income and expenses. On May 2, 1998, petitioners
submitted to respondent documentation pertaining to their claimed
casualty or theft loss, which was related to petitioners' pension
plan. They did not submit any medical expense or Schedule C
documentation.
On May 24, 1998, petitioners sent respondent a copy of their
1993 Federal income tax return and a copy of a letter respondent
sent to petitioners resolving an audit of their 1993 tax year.
After reviewing petitioners' 1993 return, respondent's examiner
narrowed the scope of the audit of petitioners' 1995 return to
their medical expenses and the pension-related casualty or theft
loss.
On May 27, 1998, respondent mailed to petitioners a report
proposing adjustments to petitioners' medical expense deductions
and the pension-related casualty or theft loss. Petitioners had
invested in a self-directed IRA with First Pension Corporation
(First Pension). In April 1994, First Pension filed for
bankruptcy, and the accounts of their investment trustee, Summit
Trust Company, were frozen. At the time of the bankruptcy
filing, petitioners' account contained a 5-acre parcel of land
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011