Gerard and Audrey Kathleen Hennessey - Page 16




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          1994 amended return was prepared on the cash basis method of                
          accounting.  ISOA, Inc.’s 1994 amended Form 1120S reflected                 
          ordinary income of $12,894.                                                 
               On or about March 19, 1997, respondent received from ISOA,             
          Inc., a Form 1120S for the taxable year beginning January 1,                
          1996, and ending August 15, 1996.  ISOA, Inc.’s 1996 return was             
          prepared on the cash basis method of accounting.  ISOA, Inc.’s              
          1996 Form 1120S reported taxable income of zero and total                   
          deductions of $69,937, for a loss of $69,937.  The total                    
          deductions included travel expenses of $22,856.                             
               On or about March 19, 1997, respondent received ISOA, Inc.’s           
          Form 1120, U.S. Corporation Income Tax Return, for the taxable              
          year beginning August 16, 1996, and ending December 31, 1996.               
          The 1996 Form 1120 reflected that the return was prepared on the            
          accrual method of accounting.  On the 1996 Form 1120, ISOA, Inc.,           
          reported total income of $446,454 and total deductions of                   
          $482,825, for a loss of $36,371.  On the balance sheet attached             
          to the Form 1120, ISOA, Inc., listed under “Other Current                   
          Liabilities” ending balances for “Royalty Payable” and “Deferred            
          And Unearned Income” of $185,500 and $195,000, respectively.                
          II.  Respondent’s Examinations                                              
               On June 12, 1996, respondent notified petitioners by letter            
          that their 1992 individual tax return had been selected for                 
          examination in respondent’s Lubbock office.  Revenue Agent Susan            







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