- 3 - practice of law. Petitioner also served as a Domestic Relations Commissioner within a three-county area in Kentucky which meant he presided over and heard divorce actions (divorce referee). Petitioner reported self-employment income in 1996 of $170,980, and claimed deductions of $110,171 attributable to the law practice, and $27,953 attributable to petitioner’s serving as a divorce referee. Respondent began examining petitioners’ income tax return for 1996 on May 18, 1999, when respondent sent petitioners a letter requesting to meet with them to obtain documentation substantiating petitioners’ income, expenses, and deductions reported on their tax return for 1996. Despite numerous requests to provide respondent the documents to substantiate the deductions, petitioners lacked adequate books and records. What little documentation petitioners provided was insufficient to substantiate the deductions. For example, petitioner provided banking information and provided the revenue agent a listing of expenses. The listing lacked dates and check numbers, however, and was merely a listing of expenses with separate amounts shown under each expense category. The revenue agent testified that many of petitioners’ bank records appeared to be personal expenses that petitioners deducted for business purposes. For example, petitioner deducted checks written to his wife for contract labor, but petitionersPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
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