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memory, estimating figures, and looking at old check registers
and assorted receipts. At the time of filing his tax returns for
the years in issue petitioner did not keep his tax records in an
organized manner.
On his 1982 tax return, petitioner reported his rental
income on line 24 (other income) of the Form 1040, and did not
provide any information as to what the properties were, what the
gross rentals were, and what the expenses were. On his Schedule
C, he reported only the total amount of the deductions (with a
breakdown of the deductions on separated sheets attached to the
tax return) but no gross receipts from any business or
profession; six of the items on the expenses breakdown are shown
as estimates. On his Schedule D, he reported a net amount for
capital gains, without showing any of the other information
required by the form. Similarly, on his Schedule E, he reported
merely a lump sum of royalty income; he did not provide any
information as to what the properties were, what the gross
royalties were, and what the expenses were. Similarly, on his
Schedule F, he reported merely a lump sum of gross income from
farming, without any of the other information required by the
form.
On his 1983 tax return, petitioner failed to attach
Schedules D and E, even though he reported on the Form 1040 that
he had income from capital gains, rents, and royalties.
On his 1984 tax return, petitioner failed to attach
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