Gerard and Audrey Kathleen Hennessey - Page 22




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          reimbursements from the University to petitioner had been equally           
          split between petitioner’s employee business expenses at the                
          University and ISOA, Inc.  Additionally, the amount of                      
          petitioner’s travel expenses at the University on a general                 
          ledger for 1993 did not equal the travel expenses claimed on the            
          1993 Form 2106.  The “general ledgers” also indicated that                  
          petitioners often claimed per diem expenses as well as hotel and            
          meal expenses for the same travel.  There were also personal                
          expenses, including women’s clothing and car rental expenses for            
          petitioners’ son, which were included on the “general ledgers”              
          and deducted by petitioners on their tax returns under                      
          examination.                                                                
               During the examination, Agent Sutton was also provided with            
          a draft audit report prepared by the University.  The draft audit           
          report raised questions regarding irregularities with respect to            
          petitioner’s expense reimbursements from the University.                    
               On May 29, 1997, after examining the information provided to           
          that date, Agent Sutton issued an IDR to petitioners with more              
          than 300 questions and document requests.  This again included,             
          in part, requests for substantiation for the claimed business               
          expense deductions, as well as an explanation of the $195,000 of            
          “Advances From Others” with respect to ISOA, Inc.’s 1995 return.8           


               8 Throughout the proceeding, the parties refer to this as              
          the “deferred income” issue.  We do likewise.                               





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