- 4 - FINDINGS OF FACT3 1. Overview a. General Some of the facts have been stipulated and are so found. The stipulations and attached exhibits are incorporated herein by this reference. Petitioners have been married for the last 33 years, and they resided in Rye, New York, when they filed their petition herein. They are cash method taxpayers, and they signed and filed 1980, 1981, and 1982 Forms 1040, U.S. Individual Income Tax Return, using the status of "Married filing joint return". Their 1980, 1981, and 1982 returns reported taxable income of $56,847, $71,010, and $5,550, respectively. Gross (and adjusted gross) income for the respective years were reported as $86,153, $107,373, and $37,766. Wages for the respective years were reported as $96,412, $111,652, and $40,166. 3 Petitioner testified at trial. Based on our observation of petitioner at trial, and following our review of the record as a whole, we conclude that petitioner's uncorroborated testimony is largely unreliable. See Kraut v. Commissioner, 527 F.2d 1014, 1019 (2d Cir. 1975), affg. 62 T.C. 420 (1974); Pepi, Inc. v. Commissioner, 448 F.2d 141, 147 (2d Cir. 1971), affg. 52 T.C. 854 (1969); O'Connor v. Commissioner, 412 F.2d 304, 311 (2d Cir. 1969), affg. in part and revg. in part T.C. Memo. 1967-174; Tokarski v. Commissioner, 87 T.C. 74, 77 (1986).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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