- 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
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 Next
Last modified: May 25, 2011