Elizabeth Giles - Page 15

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          Schedule C, petitioner reported gross income of $1,000 and total            
          expenses of $17,649.                                                        
               In 2001, petitioner reported Schedule C income of $209 and             
          adjusted gross income of $145,683.  On the attached Schedule C,             
          petitioner reported gross income of $20,000 and total expenses of           
          $19,791.                                                                    
               On March 3, 2003, respondent sent petitioner an initial                
          contact letter asking her to produce books, records, and work               
          papers used to prepare her Schedule C for 1999.  Petitioner did             
          not produce any books, records, or other work papers in response            
          to the initial contact letter.  Respondent subsequently expanded            
          the examination to include 2000 and 2001.                                   
               On March 18, 2003, respondent sent petitioner a 30-day                 
          letter covering 1999, 2000, and 2001.  Petitioner was given the             
          opportunity to sign a period of limitations extension, but                  
          refused to do so.  At the time, petitioner had already filed a              
          petition with this Court relating to 1997 and 1998.  Petitioner             
          wished to add the 1999, 2000, and 2001 years to the prior case.             
          In an effort to consolidate the cases, petitioner forewent the              
          administrative appeal process for the years in issue.  The cases            
          were never consolidated.                                                    
               On June 26, 2003, respondent mailed petitioner a notice of             
          deficiency for the years in issue.  Respondent determined that              
          petitioner’s horse activity expenses were not ordinary and                  






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