- 26 - 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.Page: Previous 19 20 21 22 23 24 25 26 27 28 29 30 31 32 33 NextLast modified: November 10, 2007