Richard D. Irving and Cynthia A. Burrough Irving - Page 4

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          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.                                                                  





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