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income, gift, and estate tax law to promote and sell these
programs to his clients. Mr. Runkle failed to maintain records
of his income and expenses for this income and estate tax
planning activity.
Failure To Maintain Adequate Records
Mr. Runkle also did not maintain books and records of his
income and expenses for his insurance sales activities, nor did
he maintain books and records for his computer sales activities
for the years at issue. Although he maintained a check register
for the years at issue, Mr. Runkle threw away his check registers
after he balanced his checking account. Mrs. Runkle destroyed
her books and records for the Canyon Kennel for the years at
issue, threw away the check registers she briefly maintained for
Canyon Kennel, and threw away the bank statements after she
balanced the bank account during the years at issue.
Petitioners’ Family Limited Partnership
Petitioners formed the Elknur4 Family Limited Partnership on
August 19, 1994.5
Petitioners have been the general partners of the Elknur
Family Limited Partnership, each holding a 2-percent interest as
4“Elknur” is Runkle spelled backwards.
5We note that this date is a mere 7 days after Revenue Agent
Andrews mailed Mr. Runkle a notification letter that respondent
was examining Mr. Runkle for failure to file returns for 1991,
1992, and 1993.
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