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workpapers include a schedule summarizing petitioner’s
documentation of her Schedule C income and expenses by category
and by year. That schedule shows, for each of the years at
issue, preliminary figures, adjusting entries, and final figures
for each category of income and expense. The workpapers also
include a summary schedule for the years at issue showing the
income and expense information used by Mr. Aunan to prepare
petitioner’s Schedule C (including depreciation claimed), a
workpaper entitled “Business Interest” that lists interest paid
on petitioner’s credit cards, a depreciation schedule that shows
how Mr. Aunan calculated the depreciation claimed on petitioner’s
Schedules C, a workpaper entitled “Personal” that lists
information regarding various Schedule A itemized deductions for
each of the years at issue, a workpaper labeled “611 Dayton”
relating to a rental property that petitioner owned and sold in
1987, and a Schedule C workpaper relating to the law practice of
petitioner’s husband.
8(...continued)
maintained that he could not tell how Mr. Aunan had combined
petitioner’s expenses to arrive at the numbers reported on her
income tax returns for the years at issue. Respondent’s claimed
inability to understand how petitioner’s business expenses were
categorized for return filing purposes led to the detailed
listing of petitioner’s expense records without regard to actual
reporting of the expenses on the relevant tax returns.
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