James L. Ball - Page 3

                                                - 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 1984                            






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