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$3,482.29, $3,567.13, and $3,651.97 for the years 1986, 1987, and
1988, respectively; (3) whether petitioner and his spouse had
taxable Social Security benefits in 1986 in the amount of $4,095;
and (4) whether petitioner has unreported taxable payments made
by the U.S. Department of Agriculture pursuant to the Soil
Conservation and Domestic Allotment Act (ASCS) in the amounts of
$11,198.96 and $11,298 for 1987 and 1988, respectively.
Background
This case was submitted fully stipulated pursuant to Rule
122. The stipulation of facts and the attached exhibits are
incorporated by this reference, and the facts contained therein
are found accordingly.
Petitioner and his spouse resided in Danville, Illinois, at
the time the petition was filed in this case.
On May 2, 1989, petitioner and his spouse filed untimely
joint Federal individual income tax returns for the years 1986,
1987, and 1988 with the Collection Division of the District
Director for Internal Revenue located in Springfield, Illinois.
Petitioner and his spouse prepared their joint Federal income tax
returns using the cash receipts and disbursements method of
accounting.
Petitioner and his spouse were engaged in farming operations
during the years 1986, 1987, and 1988. Petitioner's spouse was a
retired school teacher for the State of Illinois during the years
1986, 1987, and 1988.
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