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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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Last modified: November 10, 2007