Michael E. Thibodeaux & Stephanie R. Thibodeaux, a.k.a. Stephanie R. Hearn - Page 4

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               Throughout 1998, petitioner worked as a self-employed                  
          consultant.  From time to time during that year he entertained              
          clients and prospective clients.  To that end petitioner “picked            
          up the tab” for various meal and entertainment expenses.                    
          Petitioner “generally would keep just some loose papers or                  
          notices” evidencing these expenses, and he “would send them to              
          [his] accountant just as records of what [he] had done.”                    
               According to petitioner, his records for meal and                      
          entertainment expenses for the 1998 taxable year were lost by his           
          accountant.  Consequently, in 1999 petitioner prepared a “diary”            
          to “approximate as best [he] could” the meal and entertainment              
          expenses he incurred during 1998.  Various entries made in the              
          “diary” on numerous dates show only the name of an individual and           
          an amount.  The “diary” does not contain any notations describing           
          the business purpose of recorded expenses.                                  
               Each petitioner initially filed a separate 1998 return.                
          Stephanie Thibodeaux’s return was timely; petitioner’s return,              
          filed February 22, 2000, was not.2  On December 19, 2001,                   
          respondent received petitioners’ joint Form 1040X, Amended U.S.             
          Individual Income Tax Return, for 1998 (the joint return).  The             
          joint return includes a Schedule C for petitioner’s consulting              


               2 The parties stipulated that petitioner’s 1998 return was             
          filed Feb. 22, 2000.  The notice of deficiency suggests his                 
          return was filed Feb. 20, 2000.  The difference is without                  
          distinction and need not be reconciled.                                     





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