J. Thomas and Henrietta A. Hardin - Page 3

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          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 petitioners              






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