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returns were prepared by Franciso Javier Bencomo (Bencomo). No
income or gross receipts from Autos Oti-Juarez were reported on
petitioners’ individual Federal income tax returns for 1990,
1991, and 1992.
Autos Oti-Juarez was a cash business. Petitioner paid cash
to purchase used cars for resale. Salesmen were paid their
commissions on sales in cash. No business records from Autos
Oti-Juarez were provided to respondent's agents at any time.
Petitioners requested and received extensions to file their
1990 Federal individual income tax return, extending the due date
until October 15, 1991. Petitioners’ 1990 return was filed a
year later on October 15, 1992.
Petitioners requested and received extensions to file their
1991 Federal individual income tax return. Petitioners timely
filed their 1991 return on October 15, 1992.
Petitioners requested and received extensions to file their
1992 Federal individual income tax return, extending the due date
until October 15, 1993. Petitioners’ 1992 return was filed on
November 23, 1993.
OPINION
Respondent determined that petitioners had failed to report
income from Autos Oti-Juarez on their individual Federal income
tax returns for 1990, 1991, and 1992. Petitioners do not dispute
respondent’s determination that this income should have been
reported on their returns. Petitioners are seeking, however, to
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