- 5 - for 1996, 1997, or 1998. Petitioner did not file any Forms 941, Employer’s Quarterly Federal Tax Return, for any periods in 1996, 1997, or 1998 with the IRS with respect to these workers, nor did petitioner file any Forms 940, Employer’s Annual Federal Unemployment Tax Return, for 1996, 1997, or 1998. Finally, petitioner did not file any Forms 1041, U.S. Income Tax Return for Estates and Trusts, for 1996, 1997, or 1998. Respondent’s examination of petitioner was itself a product of the income tax examinations of petitioner’s managers, Carmel and Damigos, when they both failed to file income tax returns for the 1996 and 1997 tax years. As part of the examination of Carmel and Damigos, respondent requested that petitioner make its books and records available for inspection. When petitioner failed to provide respondent with any documents, respondent summoned the records from the banks of both Carmel and petitioner. Petitioner filed a motion to quash the summons. This motion was later dismissed, and the bank records were produced to respondent. After respondent received petitioner’s records from the banks, petitioner was referred within the IRS for an employment tax examination. A notice of examination was sent to petitioner on November 26, 2001, informing it of the examination and requesting that petitioner make certain documents related to petitioner’s business and workers available for inspection. ThisPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011