- 5 - ending inventory corresponding with the amount reported on the Schedule C. The amount shown as ending inventory ($221,908) was carried forward on other returns, including an amended return for 2000 filed for Stejskal Enterprises Trust in July 2004. Audit of petitioners’ individual returns and the returns for the various trusts commenced in 2003. Petitioners declined to meet with the Internal Revenue Service agent. The agent met with petitioners’ daughter-in-law, Bonnie Stejskal, and Janet S. Wilkerson (Wilkerson), the certified public accountant who prepared returns for petitioners and for the trusts. Bonnie Stejskal signed the 1999 Forms 1041 for Stejskal Enterprises Trust and Bioactive Kansas Trust. Among the adjustments to petitioners’ income made in the notices of deficiency was to reduce purchases by Stejskal Enterprises Trust to $397,480 and, consequently, to reduce cost of goods sold to $347,179. OPINION Paragraph 10 of the stipulation that was filed at the time of trial set forth that “Petitioners concede that they bear the burden of proof under I.R.C. sec. 7491 on all income, expense, and deduction issues to be tried.” Petitioners also conceded the negligence penalty under section 6662 and the addition to tax for failure to file timely under section 6651(a)(1). The issues forPage: Previous 1 2 3 4 5 6 7 8 Next
Last modified: May 25, 2011