- 3 - 1. Petitioner's Returns for 1984, 1985, and 1986 Petitioner's Federal income tax returns were due by April 16, 1985, for 1984, April 15, 1986, for 1985, and April 15, 1987, for 1986. Petitioner did not file those returns before 1990. In early 1990, respondent asked petitioner to file his returns for 1984, 1985, and 1986. Petitioner filed his Federal income tax returns for those years on March 30, 1990. The 1984 and 1985 returns were joint returns. However, petitioner's wife did not sign those returns when petitioner filed them. She signed the 1984 return on May 17, 1991, and the 1985 return on May 23, 1991. Petitioner's filing status for 1986 was single. 2. Respondent's Examination of Petitioner's 1984, 1985, and 1986 Returns and Assessment of Tax for Those Years Respondent examined and made adjustments to petitioner's returns. Respondent assessed the amounts of tax shown on the returns (assessed taxes), additional amounts of tax for 1984 and 1985 (over assessed taxes), and additions to tax and interest for 1984, 1985, and 1986. Petitioner reported a $1,823 tax liability on his 1984 return. Respondent disallowed petitioner's claimed Schedule C loss of $4,290 on that return. On July 16, 1990, respondent issued a statement of account to petitioner that showed a $2,509 increase in tax for petitioner's 1984 year based on those adjustments. Respondent assessed additions to petitioner's 1984Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011