- 4 -
Accordingly, petitioners reported net profit of $13,565,
representing the total income reported by petitioners on the 2001
tax return.
During the years in issue, petitioners maintained ownership
of and access to the following two bank accounts with Bank of
America: (1) Account No. xxxx xxxx 6240 under the name Richard
D. Irving d.b.a. Kingdom Kreations (Account A) and (2) Account
No. xxxx xxxx 7849 under the names Richard D. Irving and Cynthia
A. Irving (Account B). Accounts A and B are hereinafter referred
to collectively as the bank accounts. Petitioners concede that
they paid personal expenses from Account A during the years in
issue. During 2000 and 2001, Bank of America issued monthly bank
statements identifying petitioners’ transactions with respect to
the bank accounts, which bank statements are hereinafter
collectively referred to as the bank statements.
Petitioners maintained their business records with computer
software and stored the records in both electronic and paper
form. Petitioners, however, lost the electronic records due to
computer malfunction, and they subsequently destroyed the paper
records when they ceased to operate Kingdom Kreations.1
1The record does not indicate the date on which petitioners’
electronic records were lost, and the record does not indicate
the date on which petitioners ceased to operate Kingdom
Kreations.
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 Next
Last modified: May 25, 2011