- 24 - Query System at Bank of America; (3) a copy of NationsBank’s records concerning a loan to Mr. Gowni in 1996; (4) a copy of NationsBank’s records concerning a loan to Mr. Gowni in 1997; (5) a copy of NationsBank’s records concerning a loan to Mr. Gowni in 1999; and (6) a copy of NationsBank’s records concerning a loan to Ava Anthony in 1999. During the examination of the Gownis’ bank records, the IRS requested that the Gownis provide documentation and explanations as to any nontaxable items that were deposited to their personal bank accounts. The IRS received information about Mina of Sanford’s shareholder loan account in response to those requests. The examination of the Gownis’ income tax returns for 1998 and 1999 and the evaluation and analysis of their bank records and other information took approximately 1 year and consumed more than 150 hours of revenue agent time. Results of the Examination of the Gownis’ Income Tax Returns A. 1998 The IRS made the following determinations with respect to the Gownis for 1998: 1. Distributable Gain From the Sale of Property by Tomson Tomson had a $413,696 basis in the property that it sold to Sembler and recognized a $408,304 gain on the sale. The IRS determined that Tomson was an S corporation during 1998 and that $204,152 of this gain was attributable to the Gownis. BecausePage: Previous 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 Next
Last modified: May 25, 2011