Gerard and Audrey Kathleen Hennessey - Page 45




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          Petitioners had no receipts for amounts deducted as travel                  
          expenses that were allegedly paid to their daughter in exchange             
          for travel coupons.  Many questions were raised by the revenue              
          agent regarding petitioner’s reimbursements for University-                 
          related travel, but petitioners delayed responding to those                 
          questions, or failed completely to do so, even though an                    
          investigation by the University focused upon those                          
          reimbursements.17                                                           
               From their presentation at the hearing, it appears that                
          petitioners, for the most part, consider the “general ledgers”              
          provided to the examining agents as adequate substantiation for             
          the challenged deductions.  Ignoring for the moment                         
          inconsistencies from version to version, the “general ledgers”              
          provided little support for the challenged deductions.  The                 
          “general ledgers” lacked meaningful descriptions of the listed              
          expenditures or their business purpose, and, on an item by item             
          basis, the amounts reported on the “general ledgers” often did              
          not support the amounts reported on any of the returns submitted            
          by petitioners.  Contrary to the significance that petitioners              
          attribute to the “general ledgers”, in many ways, those documents           
          actually support respondent’s requests for additional information           
          for certain deductions inasmuch as entries contained in the                 

               17 Petitioner was given the opportunity at the hearing to be           
          recalled as a witness to explain the nature of the University’s             
          investigation, but she chose not to do so.                                  





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