Kenneth W. Stejskal, Sr. and Jane Stejskal, et al. - Page 5

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          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 for            







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