- 8 - 11, 2000, petitioner submitted Forms 1040 for 1994 through 1996, to an Appeals officer. Because of the information disclosed by the tax returns, the examination of 1994 through 1996 was sent back to the examination function by Appeals and reassigned to Agent Riley. Agent Riley issued petitioner an Information Document Request (IDR) asking petitioner to provide documentation and support for the income and deductions shown on his tax returns. After issuing the IDR, Agent Riley eventually received a response including information from another attorney, then representing petitioner, Brian Morris. Utilizing this information and the tax returns, Agent Riley discovered two bank accounts under the names Oneida Family Trust (OFT) and DSG. Petitioner possessed signature authority on both accounts. Following a bank deposits analysis, Agent Riley determined that petitioner understated his gross receipts on his 1994 through 1996 Federal tax returns. During a meeting with petitioner and Mr. Marshall on May 14, 2001, Agent Riley produced three binders containing photocopies of every check drawn on the two bank accounts for these years. As the expenditures exceeded the income shown on the 1994 through 1996 tax returns, Agent Riley asked how the additional funds were derived. Petitioner replied that he acquired the funds from gifts by family members. After completing the examination and allowing a number of previously disputed deductions, Agent Riley then sent the case toPage: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
Last modified: May 25, 2011