- 8 -
master's degree in electrical engineering at San Jose State
University, and a doctoral degree in electrical engineering from
the University of California at Berkeley and San Jose State
University. Mrs. Ghadiri received a bachelor's degree in German
at San Jose State University and a master's degree in math and
German at San Jose State University. Mr. Ghadiri testified that
he received approximately $680,000 in loans from acquaintances
during the years in question. During the trial, Mr. Ghadiri's
acquaintances stated that they had lent him money. Each
acquaintance that testified claimed to have canceled checks
regarding the loan but failed to bring the checks to trial.
Petitioners filed their joint 1986, 1987, and 1988 Federal
income tax returns on November 15, 1990. On August 2, 1993,
petitioners and respondent executed a Form 872-A, Special Consent
to Extend the Time to Assess Tax, extending the period of
limitation on assessment for petitioners' 1988 taxable year only.
On February 8, 1995, petitioners forwarded to respondent a Form
872-T, Notice of Termination of Special Consent to Extend the
Time to Assess Tax, with respect to petitioners' 1988 taxable
year. Respondent received the Form 872-T on February 10, 1995.
The subject notice of deficiency was mailed to petitioners on
May 12, 1995, more than 90 days after respondent received Form
872-T.
OPINION
A. Bank Deposits Analysis
Page: Previous 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 Next
Last modified: May 25, 2011