- 9 - During the years at issue, petitioner maintained banking relationships with at least two financial institutions–-ANB at which petitioner maintained two checking accounts (Nos. 302-733-1 and 109-070-3), a payroll account (No. 109-139-6), and several personal and commercial loan accounts; and First Bank at which she maintained a checking account (No. 2624676067).6 IV. Respondent’s Review of Petitioner’s Business Records Although petitioner produced her business records (ledger books, checks, cash receipts, credit card receipts, credit card statements, and other documents) to the revenue agent in connection with the examination of her returns for 1987-90, the revenue agent failed to examine and/or utilize petitioner’s records for 1987, 1989, and 1990 to ascertain the accuracy of the income and expenses claimed on petitioner’s Schedules C for those years. With the possible exception of 1988, for which a portion of petitioner’s Schedule C deductions was allowed, respondent issued the notices of deficiency without examining petitioner’s business records. A. Schedule C Income Sometime after respondent issued the notices of deficiency, respondent undertook to reconstruct petitioner’s Schedule C 6The record does not disclose when the accounts were opened and does not include complete records for the accounts. Petitioner also maintained other financial accounts during the years at issue, but the record contains minimal information concerning them.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