Gerard and Audrey Kathleen Hennessey - Page 26




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          agree with the adjustments in the proposed RARs sent on August              
          12, 1998, and requested that the returns under examination be               
          reviewed by respondent’s Appeals Office.                                    
               On August 27, 1998, respondent issued to petitioners a 30-             
          day letter for their 1993 through 1995 individual taxable years             
          and a 30-day letter for their 1996 individual taxable year.                 
          Respondent proposed deficiencies, additions to tax, and penalties           
          as follows:10                                                               
                                        Additions to tax    Penalty                   
               Year        Deficiency    sec. 6651(a)(1)   sec. 6663                  
               1993      $25,046        $2,866         $18,785                        
               1994      31,754              8,019          23,815                    
               1995      74,895         11,277              56,171                    
               1996      33,656         ---                 25,242                    

          Respondent, in part, disallowed a number of claimed business                
          expense deductions claimed by petitioners for lack of                       
          substantiation and business purpose.  Respondent also asserted              
          that several of petitioners’ claimed business expense deductions            
          were either reimbursed by the University, personal in nature, or            
          deducted multiple times among petitioners, Beacon, and ISOA, Inc.           
               On August 27, 1998, respondent issued separate 30-day                  
          letters to Beacon and ISOA, Inc., with respect to the                       
          corporations’ taxable years under examination.  The 30-day letter           


               10 Respondent and petitioners resolved the issues that arose           
          during the examination of petitioners’ 1992 individual tax return           
          with no additional tax or penalties due.                                    





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