- 15 - Special Agent Fabina learned that Mr. Runkle, on behalf of the Elknur Family Limited Partnership, purchased a Kawasaki jet ski and a trailer for approximately $2,000 from R&D Motorsports, Inc. (R&D), on June 23, 1995. Shortly thereafter, Special Agent Fabina served a summons on R&D for their books and records pertaining to all transactions involving Mr. Runkle and the Elknur Family Limited Partnership for the years at issue. Mr. Runkle advised Randy Bills of R&D that respondent was prevented by court order from obtaining records of the Elknur Family Limited Partnership, and Mr. Runkle threatened to sue Mr. Bills if Mr. Bills gave any documents to Special Agent Fabina, even though Mr. Runkle knew that there was never a court order that prevented respondent from summonsing and receiving documents and information pertaining to the Elknur Family Limited Partnership. In addition to all the actions to quash the various summonses, petitioners filed a motion to dismiss this case on February 17, 2004. Petitioners testified that they filed their motion to dismiss as a “tool” to force respondent to concede the fraudulent failure to file additions under section 6651(f) for the years at issue. Deficiency Notices By deficiency notices dated August 7, 2002, respondent determined deficiencies in, and additions to, each petitioner’s Federal income taxes as follows:Page: Previous 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 Next
Last modified: May 25, 2011