Timothy A. Runels and Emma Valdivieso Runels, et al. - Page 5




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          preparing accounts payable for Lenders Choice Network.  In 2002,            
          she had 2 or 3 years experience.  Mrs. Runels is aware that                 
          businesses and individuals keep books and records and receipts.             
               Petitioners’ Federal income tax returns for 2002, 2003, and            
          2004 were chosen for examination.  Tax Compliance Officer (TCO)             
          Carolyn Price sent the initial contact letter to petitioners.               
          The TCO was subsequently contacted by petitioners’ return                   
          preparer, who held a power of attorney (POA) for 2002.                      
          Eventually, the return preparer attended a meeting with the TCO             
          but provided “a very minimal amount of records.”  Ultimately, the           
          TCO obtained most of petitioners’ bank statements and prepared a            
          bank deposits analysis to verify petitioners’ income.  The                  
          results of the bank deposits analysis caused the TCO to make an             
          adjustment to petitioners’ gross receipts for 2002.  The TCO had            
          contact only with petitioners’ return preparer for 2002, and not            
          with petitioners.                                                           
               Petitioners failed to respond to requests from the TCO for             
          information for 2003 during the initial examination.                        
          Petitioners’ return preparer appeared before the TCO, without a             
          POA, to provide some documentation for 2004.  After the TCO                 
          prepared the audit report for 2004, petitioners requested and               
          received audit reconsideration for the year.  Petitioners                   
          disagreed with the amounts allowed for depreciation and vehicle             
          expenses.  The TCO prepared a “corrected report”, lowering the              







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