Kamil F. and Nagwa Gowni - Page 24

                                       - 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.  Because              





Page:  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