Ragnhild A. Westby - Page 18

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          testimony to explain the documentation.  Petitioner did not offer           
          into evidence any documentation of her business income and                  
          expenses for 1984-86.                                                       
          VII.  Late Filing of Petitioner’s 1987-90 Returns                           
               Petitioner filed her 1987 return on August 26, 1992, having            
          requested and received two extensions, the second of which                  
          expired on October 15, 1988.  Petitioner and Rowe filed their               
          1988 joint return on August 27, 1992, and their 1989 and 1990               
          joint returns on August 25, 1992.  Neither petitioner and Rowe              
          nor Mr. Aunan requested extensions of time to file the 1988-90              
          returns.                                                                    
               For each year at issue, petitioner gathered, organized, and            
          summarized her Schedule C information and delivered it to Mr.               
          Aunan for his use in preparing that year’s return.  For the                 
          1988-90 years, however, petitioner did not actually deliver her             
          Schedule C information to Mr. Aunan until after the return due              
          dates.  After petitioner submitted her Schedule C information to            
          Mr. Aunan, she followed up by asking him periodically what                  
          additional information he needed to complete the returns.  Mr.              
          Aunan normally responded with more requests for information;                
          within a day or two, petitioner would supply the requested                  
          information to him.  In 1992, petitioner “threatened” Mr. Aunan,            
          and the returns for all 4 years were finally completed and filed            
          in August of that year.                                                     






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