Alice Berger, et al. - Page 21

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          of Alice Berger, an application for an automatic extension of               
          time, until August 15, 1990, to file her 1989 income tax return,            
          and for an additional extension until October 15, 1990.  The                
          explanation of why the additional extension was needed states:              
          "1988 return is under audit and changes may affect 1989".  The              
          District Director approved the application for additional                   
          extension about August 20, 1990.  Alice Berger made no estimated            
          tax payments with her applications for extensions to file her               
          1989 return.  Alice Berger mailed her 1989 income tax return                
          (Form 1040) on October 12, 1990, and it was received by the                 
          Service Center on October 17, 1990.                                         
               Schedule C attached to Alice Berger's 1989 income tax return           
          reported a net loss from Woodbine of $4,101, having included                
          slightly less than one-half of Woodbine's gross income and almost           
          all of its expenses for 1989.  Attached to the return was the               
          following statement:                                                        
                Schedule C was originally prepared by Daniel Hochberg,                
               accountant for Woodbine Cemetery.  In 1989 the 1988                    
               Federal income tax return of Howard and Alice Berger                   
               was audited and accordingly, an adjustment to income                   
               was made for an additional $229,396.  This item                        
               represented deferred income that was being book [sic]                  
               for future years.  Therefore upon receipt of the RAR,                  
               this adjustment was made on the 1989 Federal tax                       
               return.                                                                
               Alice Berger reported the 1989 sale of Woodbine, using Form            
          6252 for the installment method, on her 1989 income tax return.             
          She reported the sale price of $680,000 but claimed that the                
          adjusted basis was $680,000, resulting in no reported gain or               




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