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(3) Whether the assessments for 1984, 1985, and 1986 are
barred by the statute of limitations. We hold that the
assessments are not barred.
All section 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, unless otherwise
indicated.
FINDINGS OF FACT
Some of the facts are stipulated and are so found. We
incorporate by reference the stipulation of facts and attached
exhibits.
Benjamin and Sallie Campfield (petitioners) are husband and
wife, and they resided in Trumbull, Connecticut, at the time they
filed their petition. Benjamin Campfield (petitioner) was born
in Sylvania, Georgia. His education did not proceed beyond the
seventh grade.
Arturo's, Inc.
From 1969 through 1988, petitioner was the sole shareholder
of Arturo's, Inc. (Arturo's), which operated a cafe and bar under
the name "Club 1127" in Bridgeport, Connecticut. Arturo's was
predominantly a cash business during the years 1984 through 1986.
Arturo's filed U.S. Corporation Income Tax Returns (Forms 1120)
for the fiscal years ended May 31, 1982, through 1986.
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