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Schommer and Sons has been the contractor for all
of the facilities I jointly own with my employer
here on the Corbett farm [the Rivercliff property]. I
own the cottage and an interest in the barn. My
employer owns the new house (still under construction)
and the tennis court (my wife and I don’t even play
tennis). These other facilities owned by my employer
(NCPL) are for the purpose of company use and various
entertainment for my employer and at his discretion.
(1) I do not have a complete figure, as much of the
work is still in progress. Also the portion
that is my employer’s ownership I have not
obtained his consent to release financial figures
that are not of my personal ownership interest.
(2) Various renovations first began in early 1998 and
are still ongoing as directed by my employer.
(3) I funded the cost of the Cottage renovations (our
residence) and some work on the barn. My
employer had funded the balance and considers all
of these as such, his property.
On February 18, 2004, Agent Rans mailed petitioner a Form
4564, Information Document Request, requesting: (1) Petitioner’s
Federal income tax returns for 2000, 2001, and 2002; (2) copies
of all monthly bank statements from December 1, 2000, through
January 31, 2002; and (3) records substantiating farm expenses
deducted in 2001 and 2002. Respondent also separately requested
SSI’s bank statements to determine the source of the funding for
the development of the Rivercliff property.
Petitioner provided respondent bank statements for two
accounts he held with US Bank and for one account he held with
Wells Fargo Bank. All three accounts were held in the United
States. Petitioner also provided the requested Federal income
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Last modified: March 27, 2008