- 7 - produced by petitioner is a purported "copy" of his 1991 return bearing an original signature and date of April 12, 1993. We note that the information reflected on the purported copy of petitioner's income tax return submitted to respondent's Appeals Office on April 15, 1994, corresponds to the information reflected on the substitute return prepared by the IRS. Petitioner suggests that this 1991 return was timely filed and that the IRS used information from the 1991 return in preparing the substitute return in June 1993. However, we are not convinced that the information reflected in the substitute return supports petitioner's argument that he filed a 1991 return prior to the issuance of the notice of deficiency. The June 9, 1995, IRS computer record reflecting the substitute return was not generated when the substitute return was prepared, but rather it was created in anticipation of trial. Therefore, the similarities between the amounts reflected in the substitute return prepared by respondent and the amounts reflected in the purported copy of petitioner's return do not lead us to conclude that the 1991 return was filed in 1992 or 1993. It appears probable that petitioner prepared the purported copy of the 1991 6(...continued) misspoke with respect to this assertion. Given that he filed a request for an extension on Apr. 15, 1992, and the purported copy of his 1991 return reflects a signature and date of Apr. 12, 1993, it seems unlikely that petitioner intended to testify that he filed the return in 1992. Based upon our discussion, infra, this apparent misstatement is not determinative but does reflect a certain amount of confusion and inconsistency by petitioner.Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 Next
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