Dennis E. Runkle and Debra A. Runkle - Page 7

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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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