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calculating the 1985 deficiency that respondent determined in the
instant cases.
2 Adjusted gross income is not shown on the indicated documents.
In 1989, Brown photocopied some Sley Corporations records.
She turned those records over to respondent’s agent in August
1989, and provided other information to that agent.
On June 14, 1990, respondent mailed to petitioner and Betsy
a notice of deficiency for 1986. On April 4, 1991, respondent
mailed to petitioner and Betsy a notice of deficiency for 1983,
1984, 1985, and 1987. Also on April 4, 1991, respondent mailed
to petitioner a notice of deficiency for 1988. Petitioner filed
petitions in response to these three notices of deficiency,
giving rise to the instant cases.
The notice of deficiency for 1986 was mailed more than 3
years after the 1986 tax return was filed, but within the period
agreed upon in the parties’ timely extension agreement. Sec.
6501(c)(4). The notice of deficiency for 1983, 1984, 1985, and
1987 was mailed more than 3 years after the 1983, 1984, and 1985
tax returns were filed, but within 3 years after the 1987 tax
return was filed. The notice of deficiency for 1988 was mailed
within 3 years after the 1988 tax return was filed.
Interest Expense for 1987.
At sometime before 1987, Betsy borrowed money from Markette,
a portion of which was to be repaid in 1987. Betsy wrote check
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