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restaurant, Ms. Kuykendall was assaulted and robbed at gunpoint.
She suffered from severe physical and psychological difficulties
as a result of the assault. She was subsequently diagnosed with
posttraumatic stress disorder.
Mr. Kuykendall worked as a property manager until he began
experiencing medical problems in 2002. He was diagnosed with
postpolio syndrome, a debilitating set of physiological changes
in the nervous system, which results in extreme weakness,
fatigue, and pain, among other symptoms. Mr. Kuykendall became
unable to work and suffered from very poor short term memory.
In a letter dated April 29, 2002, respondent notified
petitioners that their 1999 Federal income tax return had been
selected for review. On May 23, 2002, Ms. Kuykendall requested
that respondent delay the examination because of her medical
difficulties. Respondent’s examiner denied the request. On July
10, 2002, respondent sent petitioners an audit report showing the
changes made to petitioners’ 1999 return. Petitioners were
allowed until September 3, 2002, to submit documents pertaining
to their 1999 return. Petitioners did not respond.
On May 1, 2003, respondent issued a notice of deficiency to
petitioners’ last known address determining a tax deficiency of
$4,591 for 1999. In the notice of deficiency, respondent
disallowed petitioners’ unreimbursed employee business expenses
claimed on Schedule A, Itemized Deductions, of $18,169, and
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