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on petitioner’s Schedules C for RBS for each of the taxable years
in issue on the grounds that the income was received from
petitioner’s employer (IRS) as reimbursement for employee
business expenses.
As part of the examination, the IRS agent sent petitioner
letters on October 3, 2003, November 21, 2003, January 9, 2004,
January 30, 2004, and February 19, 2004, requesting documentary
evidence supporting his claimed business expenses. Further,
during meetings with petitioner held on November 21, 2005, May 8,
2006, and May 25, 2006, respondent requested supporting
documentation for the business expenses reported on the Schedules
C. Finally, on May 31, 2006, petitioner provided respondent with
copies of canceled checks, invoices, receipts, and newspaper
articles. Copies of these submissions are included in the
stipulated exhibits received at trial.
Petitioner’s home was burglarized on or about September 11,
2005. Petitioner informed respondent thereafter that files,
records, and information pertaining to RBS stored on petitioner’s
computer were taken in the robbery. The police investigation
report, included as part of the stipulated exhibits, lists as the
only property taken in the robbery a computer and all of the RBS-
related receipts. The report also concludes that there was no
forced entry into petitioner’s home.
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