2
All statutory references are to the Internal Revenue Code in
effect for the years in issue, and all Rule references are to the
Tax Court Rules of Practice and Procedure, except as otherwise
noted.
During the taxable years 1984, 1985, and 1986 (the period
involved herein), and when the petition was filed, petitioners
Michael K. Wolfe and Rosemarie E. Wolfe were residents of Texas.
Petitioner Rosemarie E. Wolfe did not appear at the hearing of
this case, but was represented by her husband, petitioner Michael
K. Wolfe.
Petitioners' taxable years 1985, 1986, and 1987 were
investigated by the Internal Revenue Service during 1989 and
1990. After this examination, petitioners accepted adjustments
by respondent to their income tax liability for the years 1985
and 1986. Thereafter, respondent received information concerning
the possible receipt of additional and fraudulent income by
petitioners in the years 1984, 1985, and 1986, and the
examination of these years was reopened in 1992. As a result,
substantial additional deficiencies and additions to tax for
fraud were determined by respondent, and are contained in the
notice of deficiency that was issued herein, as detailed above.
Such deficiencies and additions to tax were computed, at
petitioners' request, on the basis of petitioners being married
and filing jointly.
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