Louise Coleman, Petitioner, Fred L. Nubin, Intervenor - Page 4

                                        - 3 -                                         
          1995.                                                                       
               Petitioner and intervenor jointly filed U.S. Individual                
          Income Tax Returns, Forms 1040, for 1989 and 1990.                          
               Attached to the 1989 joint tax return is a Schedule C,                 
          Profit or Loss From Business.  The Schedule C lists the name of             
          the proprietor as Fred L. Nubin and the name of the business as             
          Fred Nubin Building Maintenance.  Attached to the 1989 joint tax            
          return is a Schedule SE, Social Security Self-Employment Tax.               
          This Schedule SE lists the name of the person with self-                    
          employment income as Fred L. Nubin.                                         
               No notices of deficiencies were issued by respondent.  On              
          May 21, 1993, Steven A. Kovary, a representative of petitioner              
          and intervenor, executed a consent to assessment and collection             
          on behalf of both of them for 1989 and 1990.  Petitioner and                
          Intervenor stipulated that they do not dispute the assessed tax             
          liabilities and additions to tax with respect to the 1989 and               
          1990 taxable years.  A large part of the liabilities was                    
          attributable to omissions of $28,408 and $23,420 of gross                   
          receipts on the Schedules C attached to the 1989 and 1990                   
          returns, respectively.  Respondent also made some minor                     
          adjustments in both years.                                                  
               Neither petitioner nor intervenor made any voluntary                   
          payments to the Commissioner with respect to their joint income             
          tax liabilities for 1989 and 1990.  Petitioner’s income tax                 






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