- 22 - 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.Page: Previous 15 16 17 18 19 20 21 22 23 24 25 26 27 28 29 NextLast modified: November 10, 2007